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Supreme Court to decide case involving death benefits paid under federal maritime and offshore drilling laws

In recent workers' compensation defense news, the Supreme Court of the United States agreed just yesterday to hear a rather interesting work comp case involving the payment of benefits under federal maritime and offshore drilling laws.

Specifically, the Supreme Court agreed to hear Pacific Operators Offshore LLP v. Luisa L. Valladolid et al., an appeal from a ruling by the 9th Circuit Court of Appeals regarding a claim for death benefits filed by Luisa Valladolid, the widow of Juan Valladolid.

According to the facts of the case, Mr. Valladolid was employed by Pacific Operators Offshore as a roustabout (i.e., an oil refinery worker) on an offshore drilling rig located roughly three miles from the California coast. He spent approximately 98 percent of his work time on this offshore drilling rig.

Mr. Valladolid's position also required that he collect scrap metal with a forklift at an onshore facility once every two years. Tragically, he was killed in an accident while performing these inland duties.

Mr. Valladolid's widow, Luisa, was able to secure death benefits from California's workers' compensation system. She also applied for death benefits under two federal laws, including Longshore and Harbor Workers' Compensation Act (LHWCA) and the Outer Continental Shelf Lands Act (OCSLA).

However, both a federal administrative law judge and a benefits review board denied the benefits claims on the grounds that Juan Valladolid was not performing maritime-related duties or working at a maritime "situs" (i.e., location) at the time of the fatal accident.

Luisa Valladolid pursued an appeal to the 9th Circuit. Here, the court upheld the decision not to award death benefits under the LHWCA, holding that Luis Valladolid was not working at a maritime "situs" at the time of the fatal accident.

However, the 9th Circuit reversed the decision regarding the death benefits payable under the OSCLA. Specifically, it found that the OSCLA does not require a worker to be injured or killed while situated on the outer continental shelf in order to secure work comp benefits. Instead, all that is required is that there is "a substantial nexus" between any injuries/death and outer continental shelf operations.

Pacific responded to the 9th Circuit decision by appealing to the U.S. Supreme Court.

Stay tuned for further developments in the area of workers' compensation defense ...

This post was provided for informational purposes only and is not to be construed as legal advice.

Related Resources:

Supreme Court to hear case of worker killed offshore (Business Insurance)

Supreme Court takes up driller's benefits appeal (Courthouse News)

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