Gulf Offshore Co. v. Mobil Oil Corp.

Mobil Oil Corporation (Mobil) (plaintiff) contracted with Gulf Offshore Company (Gulf) (defendant) for work on Mobil’s oil-drilling platforms off the coast of Louisiana. Gulf promised to indemnify Mobil for claims resulting from the work. Steven Gaedecke was a Gulf employee who worked on an offshore platform located above the Outer Continental Shelf (the shelf). Gaedecke was injured on a Mobil-chartered boat while evacuating during a hurricane and brought a personal-injury action against Mobil in Texas state court. Mobil sought indemnification from Gulf. Gulf asserted that the state court lacked subject-matter jurisdiction over Mobil’s claim because Mobil’s cause of action arose under the Outer Continental Shelf Lands Act (OCSLA), a federal statute that declared exclusive federal political jurisdiction over the shelf and granted federal district courts original jurisdiction over cases and controversies connected to operations conducted on the shelf. Congress enacted OCSLA to ensure federal control over the shelf and its mineral resources, while being mindful of the relationship between offshore-platform workers and adjacent shore communities. The Texas court rejected Gulf’s jurisdiction argument and ultimately entered a $900,000 judgment against Gulf for Gaedecke’s injuries. The state appellate court affirmed. The appellate court noted, among other things, that exclusive federal-court jurisdiction was unnecessary because in personal-injury actions involving events on the shelf, OCSLA adopted laws from the state adjacent to the events as the governing federal law. Thus, a federal court and state court would have applied the same law in Gaedecke’s action. The Texas Supreme Court denied review, and the United States Supreme Court granted certiorari.