## Facts

- Offshore workers Butley Rodrigue and Joseph Dore died in separate accidents on fixed offshore drilling platforms on the Outer Continental Shelf off Louisiana, located more than one marine league from shore.
- Dore was killed when a crane collapsed on the platform.
- Rodrigue fell to his death while testing drill pipe on a derrick above the platform, landing on the structure rather than in the sea.
- Survivors filed wrongful-death actions in federal district court asserting (1) a remedy under the Death on the High Seas Act (DOHSA) and (2) Louisiana wrongful-death remedies incorporated as federal law under the Outer Continental Shelf Lands Act (OCSLA).
- The platforms were fixed structures attached to the seabed, not used for navigation or transportation.

## Issues

1. Whether DOHSA applies to deaths occurring on fixed offshore platforms beyond one marine league from shore, making DOHSA the exclusive wrongful-death remedy.
2. Whether OCSLA instead governs deaths on fixed Outer Continental Shelf structures, incorporating the adjacent state’s wrongful-death law as surrogate federal law.

## Decision

- The Supreme Court unanimously reversed the Fifth Circuit and remanded.
- DOHSA did not govern these deaths because they occurred on fixed Outer Continental Shelf platforms treated by statute as artificial islands, not as vessels or classic maritime settings.
- OCSLA supplied the governing framework, and Louisiana law applied as surrogate federal law to the extent applicable and not inconsistent with federal law.

## Legal Principles

- OCSLA extends federal law and federal jurisdiction to the Outer Continental Shelf’s seabed, subsoil, and fixed structures, and incorporates adjacent state law as surrogate federal law when applicable and not inconsistent with federal law.
- Fixed drilling platforms on the Outer Continental Shelf are treated as artificial islands or federal enclaves for choice-of-law purposes, rather than as vessels subject to admiralty rules by default.
- DOHSA’s offshore location trigger does not displace OCSLA’s more specific statutory scheme for accidents on fixed Outer Continental Shelf structures.

## Conclusion

Wrongful-death claims arising from accidents on fixed offshore platforms on the Outer Continental Shelf are governed by OCSLA, with adjacent state law incorporated as surrogate federal law where consistent, and DOHSA does not provide the exclusive remedy merely because the platform lies beyond one marine league from shore.


Rodrigue v. Aetna Cas. & Sur. Co., 395 U.S. 352 (1969)