Gulf Offshore Co. v. Mobil Oil Corp.

453 U.S. 473 (1981)

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Nature of the Case

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Facts

Mobil (P) contracted with D for the latter to perform certain completion operations on oil drilling platforms offshore of Louisiana. As part of the contract, D promised to indemnify P for all claims resulting directly or indirectly from the work. Steven Gaedecke was an employee of P working on an oil drilling platform above the seabed of the Outer Continental Shelf. As a storm approached, a boat chartered by P took him safely aboard. While assisting crewmen attempting to evacuate other workers from the platforms in turbulent sea, he was washed across the deck of the vessel by a wave. He suffered injuries primarily to his back. P brought a suit for damages in the District Court of Harris County, a Texas state court, alleging negligence by P and the boatowner. P filed a third-party complaint for indemnification against D. D denied that the state court had subject-matter jurisdiction over the third-party complaint. D argued that the cause of action arose under the Outer Continental Shelf Lands Act (OCSLA) and that OCSLA vested exclusive subject-matter jurisdiction in a United States district court. The Texas court rejected the argument. The jury found P negligent and awarded Gaedecke $900,000 for his injuries. The jury also found, however, that Gaedecke sustained his injuries while performing work subject to the contract of indemnification. The trial judge entered judgment against D in the amount of $900,000. The Texas Court of Civil Appeals affirmed. It held that OCSLA governed the case, but found no explicit command that federal-court jurisdiction be exclusive. The Act incorporates as federal law in personal injury actions the laws of the State adjacent to the scene of the events, when not inconsistent with other federal laws. Whatever court tried the action it would have to apply the same laws no matter where the forum was located, whether state or federal. he Texas Supreme Court denied review. D appealed.