## Facts

- An explosion, fire, and sinking of the Deepwater Horizon offshore drilling unit on April 20, 2010 caused a large oil spill in the Gulf of Mexico.
- Numerous private claimants sought recovery for economic loss and property damage allegedly resulting from the spill.
- To manage consolidated proceedings, the court organized claims into pleading groups; the “B1” group covered non-governmental economic-loss and property-damage claims and included a very large number of individual claimants.
- A plaintiffs’ committee filed a B1 Master Complaint (and amendment) asserting claims under the Oil Pollution Act of 1990 (OPA), general maritime law, and selected state-law theories.
- Defendants included the well operator and related BP entities, the rig owner Transocean entities, and various contractors and manufacturers (including Halliburton, M-I Swaco, Cameron, Weatherford, Anadarko, MOEX, and others).
- Most defendants moved to dismiss under Rule 12(b)(6), challenging admiralty jurisdiction, the availability of economic-loss recovery, the viability of state-law theories, punitive damages, and pleading sufficiency as to particular defendants.

## Issues

1. Whether the spill-related tort claims fell within admiralty jurisdiction such that general maritime law governed.
2. Whether general maritime law bars recovery for “pure” economic loss absent physical damage to a proprietary interest (the Robins Dry Dock rule), and what exceptions apply.
3. Whether OPA authorizes recovery for economic loss linked to injury to property or natural resources without requiring the claimant to own the damaged property or resources.
4. How OPA interacts with general maritime law and state law, including whether and to what extent state-law claims are preempted in an admiralty case.
5. Whether punitive damages claims could proceed under general maritime law alongside OPA-based claims.
6. Whether allegations against specific categories of defendants (operators, contractors, manufacturers, and non-operating interest owners) were sufficient at the pleading stage.

## Decision

- The court found the controversy within admiralty jurisdiction and applied general maritime law, with OPA providing an additional statutory remedial scheme for oil-pollution damages.
- The court applied the maritime economic-loss limitation under Robins Dry Dock to general maritime claims, generally barring recovery for purely economic loss absent physical injury to a proprietary interest (subject to recognized maritime exceptions).
- The court held that OPA provides an affirmative cause of action for specified categories of damages, including certain economic losses “due to” injury to property or natural resources, without imposing a proprietary-interest (ownership) requirement.
- The court declined to treat OPA as wholly displacing general maritime law; it allowed maritime claims to proceed where not inconsistent with OPA’s structure.
- The court curtailed state-law theories to the extent they conflicted with governing maritime principles or otherwise failed under admiralty preemption analysis.
- The court allowed punitive damages theories to proceed under general maritime law against certain defendants where allegations supported egregious misconduct, rejecting categorical dismissal at the pleading stage.
- The court granted and denied motions to dismiss in part, preserving core OPA and maritime negligence-based claims while dismissing or narrowing incompatible or inadequately pleaded theories against certain defendants.

## Legal Principles

- Admiralty jurisdiction applies to torts sufficiently connected to traditional maritime activity and occurring on navigable waters or their functional equivalents; when it applies, general maritime law supplies default federal rules.
- Under general maritime law, Robins Dry Dock generally bars recovery for purely economic loss absent physical damage to the claimant’s proprietary interest, unless a recognized maritime exception applies.
- OPA creates statutory liability for covered oil-pollution damages and may authorize recovery for economic loss caused by injury to property or natural resources even when the claimant lacks ownership of the injured property or resources, so long as the claim fits OPA’s damage categories and causal requirements.
- OPA does not automatically extinguish general maritime remedies; maritime claims may coexist with OPA unless there is a direct conflict or impermissible duplication.
- In admiralty cases, state-law claims may be preempted when they materially conflict with federal maritime law’s uniform rules or with the governing federal statutory scheme.
- Punitive damages remain potentially available under general maritime law for sufficiently wrongful conduct unless clearly withdrawn by Congress; OPA’s silence, coupled with savings provisions, does not categorically eliminate maritime punitive damages at the pleading stage.

## Conclusion

The court sustained admiralty governance of the spill litigation, preserved the maritime bar on pure economic loss for non-OPA claims, and interpreted OPA to permit certain economic-loss recovery without an ownership requirement, while narrowing conflicting state-law theories and allowing punitive damages claims to proceed under maritime law where adequately alleged.


In re Oil Spill by the Oil Rig Deepwater Horizon, 808 F. Supp. 2d 943 (E.D. La. 2011)