Pacific Operators Offshore v. Valladolid
Issues
Whether an injured outer continental shelf worker can collect compensation benefits under the Outer Continental Shelf Lands Act when the injury occurred while working on land.
Juan Valladolid, an employee of the Petitioner, Pacific Operators Offshore, died when a forklift crushed him at Pacific's oil-processing facility on the California coast. Valladolid’s widow filed a claim for federal workers’ compensation under the Outer Continental Shelf Lands Act (“OCSLA”), but the claim was rejected because Valladolid died on land rather than on the outer continental shelf. On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed, holding that OCSLA benefits are not limited to injuries or deaths that occur on the outer continental shelf. Rather, the court held, coverage depends on the existence of a causal nexus between the injury or death and operations on the outer continental shelf. Petitioner Pacific argues that OCSLA contains a strict “situs-of-injury” requirement, while Respondent Valladolid contends that such a requirement would defeat Congressional intent. The Supreme Court’s decision will resolve a longstanding question of statutory interpretation, and may shed light on the Court’s current approach to workers’ compensation laws.
Questions as Framed for the Court by the Parties
The Outer Continental Shelf Lands Act, 43 U.S.C. §§ 1331-1356 (OCSLA), governs those who work on oil drilling platforms and other fixed structures beyond state maritime boundaries. Workers are eligible for compensation for “any injury occurring as the result of operations conducted on the outer Continental Shelf.” 43 U.S.C. § 1333(b) (2006). When an outer continental shelf worker is injured on land, is he (or his heir):
(1) always eligible for compensation, because his employer’s operations on the shelf are the but for cause of his injury (as the Third Circuit holds); or
(2) never eligible for compensation, because the Act applies only to injuries occurring on the shelf (as the Fifth Circuit holds); or
(3) sometimes eligible for compensation, because eligibility for benefits depends on the nature and extent of the factual relationship between the injury and the operations on the shelf (as the Ninth Circuit holds)?
In 1953, Congress passed the Outer Continental Shelf Lands Act (“OCSLA”) to regulate use of the outer continental shelf, defined as all submerged lands beyond the states’ three-mile coastal jurisdiction. See 43 U.S.C.
Edited by
Additional Resources
Litigation Management Magazine: Expanding Coverage: Federal Compensation Coverage for Offshore Oil Industry Workers (Fall 2011)
Mayer Brown: Supreme Court Grants Certiorari in Pacific Operations Offshore, LLP v. Valladolid (Feb. 23, 2011)
Business Insurance: Supreme Court to Hear Case of Worker Killed Offshore (Feb. 22, 2011)