On January 11, 2012, a unanimous Supreme Court issued its decision in Pacific Operators OffShore v. Valladolid, which addresses the interpretation of Section 1333(b) of the Outer Continental Shelf Lands Act (OCSLA). The text of the statute reads in full as follows:
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, or involving rights to the natural resources, of the subsoil and seabed of the outer Continental Shelf, compensation shall be payable under the provisions of the Longshore and Harbor Workers’ Compensation Act.
The correct interpretation of this section centers on the elusive words “resulting from any injury occurring as the result of operations conducted on the outer Continental Shelf.” The facts that gave rise to the dispute are as simple as the text itself. Juan Valladolid was a roustabout, or manual laborer, most of whose work involved picking up trash, emptying trash cans, swabbing texts, and assisting in operating a platform crane and other odd jobs. Most of the time, he worked on a platform located in the Outer Continental Shelf. But some small fraction of the time his jobs were land based. It was on one of those occasions that he was killed in a forklift accident related to those operations. The question was whether he could receive compensation under the OCSLA for those injuries.