Pacific Operators Offshore v. Valladolid

(Whether an offshore oil worker injured at an onshore processing site falls under the Outer Continental Shelf Lands Act and the Longshore and Harbor Workers’ Compensation Act.)

Decedent Valladolid worked for Pacific Operations Offshore as a roustabout, stationed on offshore drilling platforms. He was killed on the grounds of an onshore processing facility. His widow seeks compensation under the Longshore and Harbor Workers’ Compensation Act, as extended by the Outer Continental Shelf Lands Act. Benefits were denied under OCSLA by the Benefits Review Board because Valladolid’s injury did not occur on the outer continental shelf. The appellate court held that OCSLA does not have a “situs-of-injury” test, but rather must prove a “substantial nexus” between the injury and extraction operations on the shelf. The appellate court denied LHWCA benefits.

Petitioner argues that the OCSLA was drafted to extend federal law to the continental shelf, not to extend remedies given to those working on the shelf to those injured on dry land. Petitioner further argues that rather than read the status-based requirement of the statute to replace the situs requirement, the situs requirement should be read with the status requirement superimposed. Therefore, coverage under the Longshore and Harbor Workers’ Compensation Act should not be extended.