Gulf Offshore Co. v. Mobil Oil Corp.
69 L. Ed. 2d 784, 453 U.S. 473, 1981 U.S. LEXIS 41 (1981)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
State courts have concurrent jurisdiction with federal courts over personal injury and indemnity claims arising under the Outer Continental Shelf Lands Act (OCSLA), as the Act does not explicitly or implicitly grant exclusive jurisdiction to federal courts.
Facts:
- Mobil Oil Corp. contracted with Gulf Offshore Co. to perform operations on oil drilling platforms located on the Outer Continental Shelf off the coast of Louisiana.
- The contract contained a clause requiring Gulf Offshore to indemnify Mobil for all claims resulting from the work.
- In September 1975, workers were being evacuated from the platforms due to the approaching Hurricane Eloise.
- Steven Gaedecke, an employee of Gulf Offshore, was on a boat chartered by Mobil to assist with the evacuation.
- While on the vessel, Gaedecke was washed across the deck by a large wave and suffered severe back injuries.
Procedural Posture:
- Steven Gaedecke sued Mobil Oil Corp. in a Texas state trial court (District Court of Harris County).
- Mobil filed a third-party complaint against Gulf Offshore Co., seeking indemnification.
- Gulf Offshore moved to dismiss for lack of subject-matter jurisdiction, arguing OCSLA granted exclusive jurisdiction to federal courts.
- The Texas trial court denied the motion and, following a trial, a jury found for Gaedecke and found the indemnity agreement applied.
- The trial court entered a judgment against Gulf Offshore.
- Gulf Offshore, as appellant, appealed to the Texas Court of Civil Appeals (an intermediate appellate court), which affirmed the trial court's judgment.
- The Texas Supreme Court (the state's highest court) denied review of the case.
- The U.S. Supreme Court granted certiorari to resolve a conflict among lower courts on the jurisdictional issue.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Do federal courts have exclusive subject-matter jurisdiction over personal injury and indemnity cases arising under the Outer Continental Shelf Lands Act (OCSLA), thereby precluding state courts from hearing such cases?
Opinions:
Majority - Justice Powell
No. Federal courts do not have exclusive subject-matter jurisdiction over personal injury and indemnity cases arising under the Outer Continental Shelf Lands Act (OCSLA); state courts may exercise concurrent jurisdiction over such claims. The Court begins with the presumption that state courts share jurisdiction over federal causes of action. This presumption can only be rebutted by an explicit statutory directive, an unmistakable implication from legislative history, or a clear incompatibility between state-court jurisdiction and federal interests. OCSLA's grant of 'original jurisdiction' to federal courts is not a grant of exclusive jurisdiction. Furthermore, OCSLA's declaration that the Shelf is an area of 'exclusive federal jurisdiction' refers to political and legislative sovereignty, not judicial power. The Act's unique structure, which borrows the law of the adjacent state as surrogate federal law, is not incompatible with state-court adjudication; in fact, state judges are experts in applying that very law. Allowing state-court jurisdiction also serves the congressional policy of providing a convenient forum for workers who commute from the adjacent states.
Concurring - Justice Blackmun
No. Justice Blackmun agreed with the majority's conclusion that state courts have concurrent jurisdiction over OCSLA claims. However, he wrote separately to express reservations about the majority's discussion of the jury instruction issue, which was remanded. He argued that the purpose of OCSLA incorporating state law was to ensure local uniformity of results between the federal Shelf and adjacent state lands. Therefore, he believes that on remand, the state court should prioritize this goal of local uniformity and should not feel compelled to apply the federal common-law rule from Norfolk & Western R. Co. v. Liepelt unless there is a strong reason to displace the state rule.
Analysis:
This decision solidifies the principle of presumed concurrent jurisdiction for federal statutes, even in areas of exclusive federal political control. By distinguishing between political and judicial jurisdiction, the Court clarified that federal sovereignty over a territory does not automatically divest state courts of their power to hear related civil cases. The ruling provides plaintiffs in OCSLA cases with a crucial choice of forum, often allowing them to sue in more convenient and potentially less expensive state courts. The case also highlights the complex dynamic of OCSLA's 'surrogate law' provision, leaving open the question of when a state law becomes 'inconsistent' with federal common law, an issue to be litigated in future cases.
