Parker Drilling Management Services, Ltd. v. Newton

Where federal law addresses the relevant issue, state law is not adopted as surrogate federal law on the Outer Continental Shelf (OCS).

Off the California coast, Respondent worked for Petitioner on drilling platforms; 12 paid hours on duty and 12 unpaid hours on standby each day worked. Respondent filed a class action lawsuit for the unpaid standby time. The federal district court held the Fair Labor Standards Act constituted comprehensive law, with no gaps for state laws to fill. The Ninth Circuit vacated and remanded, holding state law is “applicable” and “pertain[s] to the subject matter at hand.” The Supreme Court vacated, and held the Outer Continental Shelf Lands Act (OCSLA) cannot adopt California law because federal law already addresses payment for standby work and minimum wage. The OCSLA extended federal laws to the Outer Continental Shelf (OCS), giving the federal government exclusive jurisdiction. When applicable and not inconsistent, the OCSLA will adopt certain state laws, which are then declared federal law for the OCS in that region. The Court explained “OCS is not, and never was, part of a state, so state law has never applied. . . " therefore if state law applied (unless federally pre-empted), much of OCSLA is unnecessary. Previous rulings have held “all law on the OCS is federal, and state law serves a supporting role, to be adopted only where there is a gap in federal law’s coverage.” OCSLA expressly invokes this federal enclave model, only adopting state laws not conflicting with federal policy. VACATED and REMANDED for further proceedings consistent with this opinion.