Pacific Operators Offshore, LLP v. Valladolid, 565 U.S. 207

OCSLA extends LHWCA coverage to injuries occurring as a result of operations conducted on the outer Continental Shelf (OCS) for extracting natural resources.
Pacific operates two offshore drilling platforms and an onshore facility; Valladolid, a roustabout, worked mostly offshore and onshore maintenance tasks.
Valladolid died in a forklift accident at the onshore facility; widow claimed LHWCA benefits under OCSLA § 1333(b).
ALJ and BRB initially held Valladolid’s death was not covered because it occurred off the OCS, prompting Ninth Circuit review.
Ninth Circuit rejected situs-of-injury and but-for interpretations, adopting a substantial-nexus test requiring a significant link between injury and on-OCS extractive operations.
Petitioner Pacific challenged the Ninth Circuit’s test and urged a situs-of-injury approach; the issue presented concerns the scope of § 1333(b) and its reach to off-OCS injuries.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does § 1333(b) require a situs of injury?	Pacific asserts a situs-of-injury requirement is implied by the text or neighboring provisions.	Respondent argues no explicit situs-of-injury requirement in § 1333(b).	No situs-of-injury requirement; expansive interpretation rejected
Does § 1333(b) cover off-OCS injuries if caused by on-OCS operations?	Valladolid’s off-OCS injury cannot be linked to OCS operations; thus not covered.	Coverage extends to injuries resulting from on-OCS operations, regardless of where injury occurs.	Yes, off-OCS injuries can be covered if caused by on-OCS operations
What test should define § 1333(b) coverage: situs, but-for, proximate cause, or substantial nexus?	Prefer a strict situs or but-for approach; the Ninth Circuit’s framework is overly broad.	But-for is too broad; proximate-cause or substantial-nexus concepts better fit the text.	Court adopts substantial-nexus test as most faithful to text; but-for rejected; proximate-cause discussed in concurrence
Should proximate-cause analysis control § 1333(b) coverage as argued by the concurrence?	Adopt proximate-cause-based limits to causation.	Majority rejects proximate-cause standard for § 1333(b).	Proximate-cause test not adopted by Court; substantial-nexus governs verdicts

Curtis v. Schlumberger Offshore Service, Inc., 849 F.2d 805 (3d Cir. 1988) (but-for approach criticized in interpreting § 1333(b))
Mills v. Director, Office of Workers’ Compensation Programs, 877 F.2d 356 (5th Cir. 1989) (en banc; but-for test used to limit § 1333(b) coverage; later reversed)
L. V. v. Pacific Operations Offshore, LLP, 42 BRBS 67 (9th Cir. 2008) (per curiam decision on geographic scope of OCSLA coverage)
Herb’s Welding, Inc. v. Gray, 470 U.S. 414 (1985) (whether injury on land can be covered by LHWCA; statutorily ambiguous in §1333(b))
Offshore Logistics, Inc. v. Tallentire, 477 U.S. 207 (1986) (situs-based approach to OCSLA coverage; footnote discussed §1333(b) scope)
Holmes v. Securities Investor Protection Corp., 503 U.S. 258 (1992) (proximate-cause approach used to interpret statutory causation language)
Brown v. Gardner, 513 U.S. 115 (1994) (proximate-cause in no-fault compensation context)
Complete Auto Transit, Inc. v. Brady, 430 U.S. 274 (1977) (substantial nexus as a test in Commerce Clause context)
Russello v. United States, 464 U.S. 16 (1983) (presumption about intent when Congress omits language)
Exxon Co., U.S.A. v. Sofee, Inc., 517 U.S. 830 (1996) (proximate-cause framework guidance in causation analysis)