Offshore Logistics, Inc. v. Tallentire

Corrine Taylor and Beth Tallentire (plaintiffs) were the widows of two offshore-drilling-platform workers who were killed in the crash of a helicopter owned and operated by Offshore Logistics, Inc. (defendant). The crash occurred approximately 35 miles off the coast of Louisiana when the men were being transported by the helicopter from a drilling platform back to shore. Taylor and Tallentire sued Offshore Logistics under the Death on the High Seas Act (DOHSA), the Outer Continental Shelf Lands Act (OCSLA), and the Louisiana wrongful-death statute. The actions were consolidated in federal court in Louisiana. Offshore Logistics moved for partial summary judgment, claiming that DOHSA provided the sole remedy for the claim and seeking the dismissal of the claims under OCSLA and the state law. The district court granted the motion, agreeing that the cause of action fell exclusively under DOHSA. Offshore Logistics admitted liability, and the court awarded damages for pecuniary loss, as allowed under DOHSA, but not for any nonpecuniary losses, which were not provided under the statute. Taylor and Tallentire appealed the dismissal of their claims under OCSLA and the Louisiana wrongful-death statute. The court of appeals reversed the district court’s decision, holding that Taylor and Tallentire could seek recovery under the Louisiana state law. Offshore Logistics appealed.