Rodrigue v. Aetna Casualty & Surety Co.

Background

Two men, Dore and Rodrigue, died while working on artificial island drilling rigs built on the outer Continental Shelf off Louisiana. Each man’s family sued in federal court under the Death on the High Seas Act and also sought additional recovery under Louisiana law as adopted by the Outer Continental Shelf Lands Act. The district courts and the Fifth Circuit treated the Seas Act as the exclusive remedy and dismissed the state-law claims.

Reasoning

The Court asked whether deaths on these fixed offshore platforms fall under the Seas Act’s admiralty remedy or instead are governed by the Lands Act’s adoption of adjacent State law as federal law. The Court explained that the Lands Act treats artificial islands as federal enclaves within an adjacent State and was enacted to use state law to fill federal gaps. The Seas Act applies only to wrongful deaths “on the high seas,” and traditional admiralty principles do not extend to these stationary structures. Because Congress deliberately rejected treating the platforms as vessels, the Court held that Louisiana law, adopted by the Lands Act, applies here.

Real world impact

The decision reverses the lower courts and sends the cases back so the families can pursue claims under Louisiana law as incorporated into federal law by the Lands Act. Offshore workers’ families can seek state-law remedies that may include damages beyond the pecuniary limits of the Seas Act. The ruling changes which laws and remedies apply to accidents on fixed offshore platforms and will affect future injury and death claims on such structures.