Parker Drilling Management Services v. Newton
In brief
The Supreme Court sent Parker Drilling back to the Ninth Circuit, deciding that state law fills gaps in federal law but does not replace federal rules that already cover the issue.
- Where it stands
- Decided
Decided 9-0 · June 10, 2019 · Opinion by Justice Thomas
- What it’s about
- This case asked whether California wage-and-hour rules applied to workers on offshore drilling platforms on the Outer Continental Shelf, where federal law generally controls.
- Who it affects
- State law can apply on the Outer Continental Shelf only when federal law leaves a gap. Claims based on California's standby-pay and minimum-wage rules fail to the extent federal law already covers those issues, while other claims remain unresolved.
Summary: written with AI from the case record.
What it's about
The Court held that state law can be adopted there only to fill a gap in federal law, not whenever the state rule relates to the dispute.
The Outer Continental Shelf Lands Act (OCSLA) sets rules for when state law can fill gaps in federal law on offshore areas under federal control.
Question presented
Whether, under OCSLA, state law is borrowed as the applicable federal law only when there is a gap in the coverage of federal law, as the Fifth Circuit has held, or whenever state law pertains to the subject matter of a lawsuit and · is not preempted by inconsistent federal law, as the Ninth Circuit has held.
What the Court decided
Holding
Under the proper standard, some of Newton’s present claims can be resolved, though others have not been analyzed by the Ninth Circuit. Some claims are premised on the adoption of California law requiring payment for all standby time. Because federal law already addresses this issue, California law does not provide the rule of decision on the OCS. To the extent Newton’s OCS-based claims rely on that law, they necessarily fail. Likewise, to the extent his OCS-based claims rely on the adoption of California’s minimum wage, the FLSA already provides for a minimum wage, so the state minimum wage is not adopted as federal law and does not apply on the OCS. 881 F. 3d 1078 and 888 F. 3d 1085, vacated and remanded.
- Result
- Vacated
The vote
What's next
The case returns to the Ninth Circuit for further proceedings. That court must apply the Supreme Court's rule and address Newton's claims that it had not yet analyzed.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Opinion added: opinion
Brief added: Petition
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Court Order added: Lower Court Orders/Opinions
Brief added: Questions Presented
More questions
- What did the Supreme Court decide in Parker Drilling v. Newton?
- State law can apply on the Outer Continental Shelf only to fill a gap in federal law. It does not apply when federal law already covers the issue.
- How did the justices vote in Parker Drilling?
- The Court was unanimous. Justice Thomas delivered the opinion for the Court.
- Did California's standby-pay and minimum-wage rules apply to Newton's offshore claims?
- Not to the extent Newton's claims relied on issues already covered by federal law. Those claims therefore fail under the Supreme Court's standard.
- What remains unresolved in Parker Drilling?
- The Ninth Circuit had not analyzed some of Newton's claims. The Supreme Court sent the case back for that court to address them.
- What happens next in Parker Drilling v. Newton?
- The Ninth Circuit will reconsider the case under the Supreme Court's rule and conduct further proceedings.
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.