Case Law Alerts
U.S. Supreme Court holds that, under the Outer Continental Shelf Lands Act, when federal law addresses a relevant issue, state law is inapplicable.
In a unanimous opinion, the United States Supreme Court held that, “to the extent federal law applies to a particular issue, state law is inapplicable” under the Outer Continental Shelf Lands Act. The plaintiff, Brian Newton, was employed by Parker Drilling Management Services on a drilling platform on the Outer Continental Shelf (OCS) off the coast of California. He worked 14-day shifts, which involved 12 hours per day on duty and 12 hours per day on standby, during which he could not leave the platform. Although he was paid above the California and federal minimum wages for his time on duty, he was not paid for his standby time. As such, he filed suit against Parker in California state court, claiming that California’s wage and hour laws required Parker to compensate him for his standby time. The issue before the Court was whether California’s laws were “applicable and not inconsistent” with federal law in order to be deemed to be surrogate federal law to be applied on the OCS. The Court explained that, since the federal government has exclusive jurisdiction over the OCS, federal law is the only law applicable on the OCS. Since federal law (the Fair Labor Standards Act) already addresses the issues of wages and hours for time an employee spends on standby, the Court concluded that California state law as to those issues was inapplicable on the OCS.
Case Law Alerts, 4th Quarter, October 2019
Case Law Alerts is prepared by Marshall Dennehey Warner Coleman & Goggin to provide information on recent developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. Copyright © 2019 Marshall Dennehey Warner Coleman & Goggin, all rights reserved. This article may not be reprinted without the express written permission of our firm.