Offshore worker injury coverage
Pacific Operators Offshore, LLP v. Valladolid
In brief
The Court agreed with the Ninth Circuit that coverage depends on a substantial connection to Pacific Operators’ offshore extraction work, not just where Juan Valladolid was injured.
- Where it stands
- Decided
Decided 9-0 · January 11, 2012 · Opinion by Justice Thomas
- What it’s about
- Juan Valladolid died at an onshore facility; his widow sought workers’ compensation under a law covering offshore operations.
- Who it affects
- A worker’s injury need not happen on the offshore shelf, but coverage requires a substantial connection to the employer’s offshore extraction work.
Summary: written with AI from the case record.
What it's about
The Court agreed with the Ninth Circuit and sent the case back to the lower court (remanded), ruling coverage requires a substantial connection between Valladolid’s injury and Pacific Operators Offshore’s offshore extraction work; whether that link exists remains unresolved.
Juan Valladolid died at an onshore facility. His widow, Luisa, sought workers’ compensation under a federal law tied to offshore resource operations.
The Outer Continental Shelf Lands Act extends workers’ compensation coverage to injuries tied to certain work exploring for, developing, removing, or transporting natural resources from the offshore shelf.
Question presented
The Outer Continental Shelf Lands Act extends workers' compensation coverage under the Longshore and Harbor Workers' Compensation Act "with respect to disability or death of an employee resulting from any injury occurring as the result of operations conducted on the outer Continental Shelf for the purpose of exploring for, developing, removing, or transporting by pipeline the natural resources of the outer Continental Shelf." Does the OCSLA extend Longshore Act coverage only to workers injured on the outer Continental Shelf itself?
What the Court decided
Holding
The OCSLA extends coverage to an employee who can establish a substantial nexus between his injury and his employer’s extractive operations on the OCS. 604 F. 3d 1126, affirmed and remanded.
- Result
- Affirmed
The Court's reasoning
The Court read the law to require a substantial connection between an injury and the employer’s offshore extraction work. It said coverage does not depend only on where the injury happened.
The vote
- Joined the judgment
- Concurred in a separate opinion
- Wrote an opinion
- Majority · 7joined the Court's opinion
- Concurring · 2agreed with the result, wrote separately
- Scaliawrote separately
- Alito
What's next
The Benefits Review Board must decide whether Juan’s injury had the required connection to Pacific Operators’ offshore work. The Supreme Court did not decide whether Luisa qualifies for benefits.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - Valladolid
Opinion added: Valladolid
More questions
- What test did Justice Scalia favor?
- He favored requiring the injury to be legally caused (proximately caused) by operations on the outer continental shelf.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.