Chevron Oil Co. v. Huson
Headline: Offshore drill worker's injury suit: Court says state time limits generally control under federal law but refuses to apply Louisiana's one-year limit retroactively, so worker keeps his chance to sue.
Holding: The Court held that the Outer Continental Shelf Lands Act requires federal courts to apply the adjacent State's statute of limitations to personal-injury claims, but it will not apply Louisiana's one-year limit retroactively in this case.
- Requires federal courts to apply adjacent State time limits for offshore injury claims.
- Blocks using admiralty 'laches' defense as a federal shortcut to avoid state time limits.
- Preserves lawsuits filed before the Court’s change by declining retroactive application of the state limit.
Summary
Background
In December 1965 a worker on an artificial island drilling rig owned by an oil company was injured. He did not sue until January 1968 after discovering the seriousness of his back injury. The suit was filed in federal court under the Outer Continental Shelf Lands Act, which makes federal courts apply state laws that are not inconsistent with federal law to injuries on fixed offshore structures.
Reasoning
The Court addressed whether federal or Louisiana law controls how long the worker had to file, and whether an old maritime fairness rule based on delay (laches) could bar the suit. The Court said Rodrigue established that state law, including its time limits, normally fills gaps in federal law created by the Lands Act. The Court rejected the lower court’s attempt to recreate laches as federal common law and held the state one-year limit is ordinarily the rule to apply.
Real world impact
Because the worker filed his lawsuit before the Court announced Rodrigue, the Court decided it would be unfair to apply Louisiana's one-year limit retroactively and leave him without any remedy. The Court therefore affirmed the appeals court result sending the case back for trial, while clarifying that future offshore injury claims are governed by the adjacent State's statutes of limitations.
Dissents or concurrances
A separate opinion agreed with letting the worker proceed but emphasized that Louisiana's one-year rule is 'prescriptive' (it bars the remedy but not the right) and argued federal courts should apply the Louisiana rule as interpreted, supporting the outcome without deciding retroactivity.
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