SCOTUS Rules on OCSLA Case - Pacific Operators Offshore, LLP v. Valladolid

News Flash - the Supreme Court issued a decision in Pacific Operations Offshore, LLP v. Valladolid, an Outer Continental Shelf Lands Act/Longshore Act case arising from the Ninth Circuit.  The Supreme Court affirmed the Ninth Circuit's decision, rejecting the approaches adopted by the Third Circuit Court of Appeals and the Fifth Circuit Court of Appeals. 

The decision is here. 

The Question Presented was:

The court granted review for this question presented:

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); 

(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)?

The opinion, authored by Justice Thomas, holds that the Ninth Circuit's "substantial nexus" test was the most supportable reading of the statutes at play here.  Justice Scalia concurred, joined by Justice Alito, that favored the adoption of a "proximate cause" test instead of the "substantial nexus" test which he thought unworkable.

Previous posts on case: Ninth Circuit Decision; Cert Petition.

Transcript of oral argument: Transcript - 10-507,