## Facts

- Juan Valladolid worked as a roustabout for Pacific Operators Offshore, LLP.
- He spent about 98% of his work time on an offshore drilling platform on the Outer Continental Shelf.
- He was killed at Pacific’s onshore oil-processing facility when a forklift crushed him.
- His widow sought federal workers’ compensation benefits under the Longshore and Harbor Workers’ Compensation Act (LHWCA) as extended by the Outer Continental Shelf Lands Act (OCSLA), 43 U.S.C. § 1333(b).
- An administrative law judge dismissed the OCSLA-based claim because the fatal injury occurred on land.
- The Benefits Review Board affirmed, applying a strict situs-of-injury approach limiting coverage to injuries occurring on the Shelf.
- The Ninth Circuit reversed and applied a “substantial nexus” requirement between the injury and the employer’s Shelf operations.
- The Supreme Court granted certiorari to resolve disagreement among circuits over the proper coverage standard.

## Issues

1. Whether OCSLA § 1333(b) limits LHWCA coverage to injuries occurring on the Outer Continental Shelf (a strict situs requirement).
2. Whether OCSLA § 1333(b) extends coverage to any injury that would not have occurred “but for” employment connected to Shelf operations.
3. What causal connection between an injury and OCS extractive operations is required for OCSLA-based LHWCA coverage when the injury occurs off the Shelf.

## Decision

- The Supreme Court affirmed the Ninth Circuit’s judgment and rejected both a strict situs-of-injury test and a pure but-for causation test.
- The Court held that OCSLA extends LHWCA coverage to an employee who establishes a “substantial nexus” between the injury and the employer’s extractive operations on the Outer Continental Shelf.
- The Court described the required nexus as a “significant causal link” between the injury and the employer’s Shelf operations conducted for resource extraction purposes.
- The Court remanded for application of the substantial-nexus standard to the facts, rather than deciding coverage on the merits in the first instance.

## Legal Principles

- OCSLA § 1333(b) extends LHWCA coverage to disability or death resulting from an injury occurring “as the result of” operations conducted on the Outer Continental Shelf for specified resource-extraction purposes.
- The statutory phrase “as the result of” imposes a causation requirement and does not create a geographic situs limitation.
- A strict requirement that the injury occur on the Shelf adds a limitation not found in § 1333(b)’s text.
- A pure but-for test is overinclusive because it can capture injuries with remote or attenuated connections to Shelf operations.
- The correct standard requires a fact-specific showing of a substantial nexus (significant causal link) between the injury and the employer’s extractive operations on the Shelf.

## Conclusion

OCSLA-based LHWCA coverage does not depend on where an injury occurs, but on whether the injury bears a substantial nexus—i.e., a significant causal link—to the employer’s extractive operations on the Outer Continental Shelf; the case was remanded for that standard’s application.


Pac. Operators Offshore, LLP v. Valladolid, 565 U.S. 207 (2012)