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Parker Drilling Management Services, Ltd. v. Newton

United States Supreme Court

June 10, 2019


          Argued April 16, 2019


         Respondent Brian Newton worked for petitioner Parker Drilling Management Services on drilling platforms off the California coast. Newton was paid for his time on duty but not for his time on standby, during which he could not leave the platform. Newton filed a class action in state court, alleging, as relevant here, that California's minimum-wage and overtime laws required Parker to compensate him for his standby time. Parker removed the action to Federal District Court. The parties agreed that Parker's platforms were subject to the Outer Continental Shelf Lands Act (OCSLA), which provides that all law on the Outer Continental Shelf (OCS) is federal law, administered by federal officials; denies States any interest in or jurisdiction over the OCS; and deems the adjacent State's laws to be federal law only "[t]o the extent that they are applicable and not inconsistent with" other federal law, 43 U.S.C. §1333(a)(2)(A). The District Court concluded that the state laws relevant here should not be applied as federal law on the OCS because the Fair Labor Standards Act of 1938 (FLSA), a comprehensive federal wage-and-hour scheme, left no significant gap in federal law for state law to fill. It thus granted Parker judgment on the pleadings. The Ninth Circuit vacated and remanded. It held that state law is "applicable" under the OCSLA if it pertains to the subject matter at issue, a standard satisfied by California wage-and-hour laws. It also held that those state laws were not "inconsistent" with federal law because they were not incompatible with the federal scheme.


1. Where federal law addresses the relevant issue, state law is not adopted as surrogate federal law on the OCS. Pp. 3-14.
(a) After this Court held that the Federal Government has exclusive jurisdiction over the entire continental shelf, see, e.g., United States v. Louisiana, 339 U.S. 699, 705, Congress enacted the Submerged Lands Act, which ceded certain offshore lands to the coastal States, and passed the OCSLA, which affirmed the Federal Government's exclusive control over the OCS. Pp. 3-4.
(b) Newton argues that state law is "applicable" on the OCS whenever it pertains to the subject matter at issue and that it is "inconsistent" only if it would be pre-empted under ordinary preemption principles. Parker counters that state law is not "applicable" absent a gap in federal law that needs to be filled and that state law can be "inconsistent" with federal law even if it is possible to satisfy both sets of laws. Parker's approach is more persuasive. This Court reads the statute's words" 'in their context and with a view to their place in the overall statutory scheme.'" Roberts v. Sea-Land Services, Inc., 566 U.S. 93, 101. The Court's pre-OCSLA decisions made clear that federal law controlled the OCS in every respect, and the OCSLA reaffirmed that role. Taken together, the OCSLA's provisions convincingly show that state laws can be "applicable and not inconsistent" with federal law under §1333(a)(2)(A) only if federal law does not address the relevant issue. The OCSLA makes apparent "that federal law is 'exclusive' . . . and that state law is adopted only as surrogate federal law." Rodrigue v. Aetna Casualty & Surety Co., 395 U.S. 352, 357. It borrows only certain state laws, which are then declared to be federal law and administered by federal officials. It would thus make little sense to treat the OCS as a mere extension of the adjacent State, where state law applies unless it conflicts with federal law. That type of pre-emption analysis applies only where overlapping, dual state and federal jurisdiction makes it necessary to decide which law takes precedence. But federal law is the only law on the OCS and there is no overlapping state and federal jurisdiction, so the reference to "not inconsistent" state laws presents only the question whether federal law has already addressed the relevant issue. If so, state law on the issue is inapplicable. Pp. 5-8.
(c) This interpretation is supported by several other considerations. Pp. 8-14.
(1) Newton's interpretation-that the choice-of-law question on the OCS is the same as it would be in an adjacent State-would deprive much of the OCSLA of any import, violating the" 'cardinal principle' of interpretation that courts 'must give effect, if possible, to every clause and word of a statute.'" Loughrin v. United States, 573 U.S. 351, 358. Pp. 8-9.
(2) This Court's interpretation is consistent with the federal-enclave model and the historical development of the statute. The OCSLA treats the OCS as "an upland federal enclave." Rodrigue, supra, at 366. Generally, when an area in a State becomes a federal enclave, "only the [state] law in effect at the time of the transfer of jurisdiction continues in force" as surrogate federal law, James Stewart & Co. v. Sadrakula, 309 U.S. 94, 100, provided that the state law does not conflict with "federal policy," Paul v. United States, 371 U.S. 245, 269. Going forward, state law presumptively does not apply to the enclave. See Sadrakula, supra, at 100. As originally enacted, the OCSLA both treated the OCS as a federal enclave and adopted only the "applicable and not inconsistent" laws of the adjacent State in effect as of the Act's effective date. This suggests that, like the general enclave rule, the OCSLA sought to make all OCS law federal yet also "provide a sufficiently detailed legal framework to govern life" on the OCS. Shell Oil Co. v. Iowa Dept. of Revenue, 488 U.S. 19, 27. Providing a sufficient legal structure to accomplish that purpose eliminated the need to adopt new state laws. The OCSLAs text and context thus suggest that state law is not adopted to govern the OCS where federal law is on point. The later amendment of the OCSLA to adopt state law on an ongoing basis confirms the connection between the OCSLA and the federal enclave model. Pp. 9-11.
(3) This Court's interpretation accords with precedent construing the OCSLA. In Rodrigue, supra, at 352-353; Chevron Oil Co. v. Huson, 404 U.S. 97; and Gulf Offshore Co. v. Mobil Oil Corp., 453 U.S. 473, the Court viewed the OCSLA as adopting state law to fill in federal-law gaps. Pp. 11-14.
2. Under the proper standard, some of Newton's present claims can be resolved, though others have not been analyzed by the Ninth Circuit. Some claims are premised on the adoption of California law requiring payment for all standby time. Because federal law already addresses this issue, California law does not provide the rule of decision on the OCS. To the extent Newton's OCS-based claims rely on that law, they necessarily fail. Likewise, to the extent his OCS-based claims rely on the adoption of California's minimum wage, the FLSA already provides for a minimum wage, so the state minimum wage is not adopted as federal law and does not apply on the OCS. Pp. 14- 15.

881 F.3d 1078 and 888 F.3d 1085, vacated and remanded.

          THOMAS, J., delivered the opinion for a unanimous Court.



         The Outer Continental Shelf Lands Act (OCSLA), 67 Stat. 462, 43 U.S.C. §1331 et seq., extends federal law to the subsoil and seabed of the Outer Continental Shelf and all attachments thereon (OCS). Under the OCSLA, all law on the OCS is federal law, administered by federal officials. The OCSLA denies States any interest in or jurisdiction over the OCS, and it deems the adjacent State's laws to be federal law "[t]o the extent that they are applicable and not inconsistent with" other federal law. ยง 1333(a)(2)(A). The question before us is how to determine which state laws meet this requirement and therefore should be adopted as federal law. ...

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