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Chevron Oil Co. v. Huson

404 U.S. 97 (1971)

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Chevron Oil Co. v. Huson

United States Supreme Court

404 U.S. 97 (1971)

Facts

In December 1965, Gaines Ted Huson (plaintiff) injured his back while working on a drilling rig off the coast of Louisiana owned by Chevron Oil Co. (Chevron) (defendant). Huson did not immediately realize that his injury was serious. In January 1968, Huson filed a personal-injury lawsuit against Chevron in federal district court. Because the drilling rig was located on the Outer Continental Shelf, the Outer Continental Shelf Lands Act governed the case. When Huson filed his lawsuit, federal precedent allowed the equitable doctrine of laches to apply to Outer Continental Shelf Lands Act cases. Under that doctrine, Huson’s case was allowed to continue because Chevron did not question the timeliness of his lawsuit. While Huson’s case was pending, the United States Supreme Court decided Rodrigue v. Aetna Casualty & Surety Co., 395 U.S. 352 (1969), holding that Louisiana’s one-year statute of limitations on personal-injury lawsuits governed the timeliness of Outer Continental Shelf Lands Act cases. Relying on Rodrigue, the district court held that Huson’s case was untimely and granted summary judgment to Chevron. Huson appealed, arguing that Rodrigue should not apply retroactively to cases filed before Rodrigue was decided. The court of appeals held that Rodrigue did not require a court to apply Louisiana’s statute of limitations and reversed the district court. Chevron appealed.

Rule of Law

Issue

Holding and Reasoning (Stewart, J.)

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