## Facts

- Gaines Ted Huson injured his back in December 1965 while working on Chevron Oil Company’s fixed “artificial island” drilling rig on the Outer Continental Shelf off Louisiana.
- The injury’s seriousness allegedly became apparent only months later.
- In January 1968, Huson filed a personal-injury action against Chevron in federal court.
- The Outer Continental Shelf Lands Act (OCSLA) makes the law of the adjacent state applicable as federal law to the extent it is applicable and not inconsistent with federal law.
- At the time Huson filed suit, prevailing precedent treated such claims as governed by admiralty principles, including laches, rather than a fixed state statute of limitations.
- While the case was pending, the Supreme Court held in Rodrigue that accidents on fixed structures on the Shelf are governed by adjacent state law under OCSLA, not admiralty.

## Issues

1. Under OCSLA (as interpreted by Rodrigue), must federal courts apply the adjacent state’s statute of limitations to personal-injury claims arising on fixed structures on the Outer Continental Shelf?
2. If so, should that limitations rule apply retroactively to bar a suit filed before Rodrigue when existing precedent indicated admiralty laches governed?

## Decision

- The Supreme Court affirmed the judgment permitting Huson’s action to proceed, but rejected the court of appeals’ rationale.
- The Court held that, after Rodrigue, OCSLA requires application of the adjacent state’s statute of limitations to fixed-structure Shelf tort claims, and courts may not substitute admiralty laches to avoid that time bar.
- The Court nevertheless held that Rodrigue would not be applied retroactively to bar Huson’s already-filed action.
- Louisiana’s one-year limitations period therefore did not bar Huson’s suit in this case.

## Legal Principles

- Under OCSLA for torts on fixed structures on the Outer Continental Shelf, adjacent state law applies as federal law, including the state statute of limitations, when applicable and not inconsistent with federal law.
- A federal court may not use admiralty laches as a federal common-law substitute to circumvent an applicable state limitations period governing the claim.
- In deciding whether a judicial decision should be applied non-retroactively in a civil case, courts consider: (1) whether the decision established a new principle of law that was not clearly foreshadowed or displaced clear precedent on which parties relied; (2) whether retroactive application would further or hinder the rule’s purpose and effect; and (3) whether retroactivity would produce substantial inequity, including depriving a party of any remedy based on an unforeseeable change in law.

## Conclusion

OCSLA generally requires federal courts to apply the adjacent state’s limitations period to personal-injury actions arising on fixed structures on the Outer Continental Shelf, but the Court refused to apply Rodrigue retroactively to extinguish a claim filed under a prior, reasonable reliance on admiralty laches.


Chevron Oil Co. v. Huson, 404 U.S. 97 (1971)