Pacific Operators Offshore, LLP v. Valladolid

565 U.S. 207, 132 S.Ct. 680, 181 L.Ed.2d 675, 2021 AMC 1 (2012)

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Pacific Operators Offshore, LLP v. Valladolid

United States Supreme Court
565 U.S. 207, 132 S.Ct. 680, 181 L.Ed.2d 675, 2021 AMC 1 (2012)

Facts

Juan Valladolid worked as a manual laborer for Pacific Operators Offshore, LLP (defendant), a company that operated offshore drilling platforms on the outer continental shelf, as well as an onshore oil- and gas-processing facility. Valladolid spent about 98 percent of his time working on the drilling platforms and the remaining time at the onshore facility. Valladolid was killed in a forklift accident at the onshore facility. Luisa Valladolid (Luisa) (plaintiff), Juan’s widow, filed a claim for benefits under the Longshore and Harbor Workers’ Compensation Act (LHWCA) pursuant to an extension of the act to cover offshore workers. The administrative-law judge dismissed the claim because the accident occurred on land. The Benefits Review Board affirmed the decision, and Luisa appealed. The court of appeals reversed and remanded the case to the Benefits Review Board to apply a substantial-nexus test to the issue of coverage. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

Concurrence (Scalia, J.)

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