Pacific Operators Offshore, LLP v. Valladolid

To receive compensation under the Outer Continental Shelf Lands Act, an employee need not have been injured while physically on the Outer Continental Shelf, but instead must establish a substantial nexus between his injury and his employer’s operations on the Outer Continental Shelf.

Respondent Valladolid’s husband, who worked primarily on Pacific Operators Offshore, LLP’s (Pacific) offshore drilling platforms, was killed in a forklift accident while working at Pacific’s onshore processing facility. Valladolid filed a claim for benefits under the Longshore and Harbor Workers’ Compensation Act (LHWCA) which was extended through the Outer Continental Shelf Lands Act (OCSLA) to include injuries “occurring as the result of operations conducted on the Outer Continental Shelf” (OCS) 43 U. S. C. §1333(b), but because Valladolid’s husband was killed on land and not on the OCS, an Administrative Law Judge (ALJ) dismissed Valladolid’s claim. The U.S. Department of Labor’s Benefits Review Board affirmed the ALJ’s decision. The Ninth Circuit Court of Appeals reversed, holding that the employee need not have been injured while physically on the Outer Continental Shelf, but instead need only establish a substantial nexus between his injury and his employer’s operations on the Outer Continental Shelf.

The Supreme Court granted certiorari in order to resolve a circuit split and affirmed the Ninth Circuit Court’s “substantial-nexus” test while rejecting both the Fifth Circuit’s “situs of injury” test and the Third Circuit’s “but-for causation” test.