Chevron Oil Company v. Huson
Respondent was injured in December 1965 while working on petitioner's artificial island drilling rig, located on the Outer Continental Shelf off the Louisiana coast. Allegedly, not until many months later were the injuries discovered to be serious. In January 1968 respondent brought suit for damages against petitioner in federal district court. The District Court, relying on Rodrigue v. Aetna Casualty & Surety Co., 395 U.S. 352, 89 S.Ct. 1835, 23 L.Ed.2d 360 (1969), held that Louisiana's one-year limitation on personal injury actions applied rather than the admiralty laches doctrine, and granted petitioner's motion for summary judgment. Rodrigue had held that state law and not admiralty law applied to fixed structures on the Outer Continental Shelf under the Outer Continental Shelf Lands Act (hereinafter Lands Act), and extended to that area as federal laws the laws of the adjacent State 'to the extent that they are applicable and not inconsistent' with federal laws. Respondent argued on appeal that in view of pre-Rodrigue jurisprudence making admiralty law (including the laches doctrine) applicable, it would be unfair to give that decision retrospective effect. The Court of Appeals, not reaching that argument, reversed, holding that Louisiana's 'prescriptive' time limitation, which barred the remedy but did nto extinguish the right to recovery, was not binding outside a Louisiana forum. Consequently, the court concluded that the time limitation was not 'applicable' of its own force and was 'inconsistent' with the admiralty laches doctrine, which though not directly applicable by virtue of Rodrigue was applicable as a matter of federal common law. Held:
1. The Lands Act, as interpreted in Rodrigue, requires that a State's statute of limitations be applied to actions for personal injuries occurring on fixed structures on the Outer Continental Shelf. The fact that the Louisiana law is 'prescriptive' does not make it inapplicable as federal law under the Lands Act, and a federal court may not apply a laches test to preclude application of the state time limitation. Pp. 100-105.
2. The Louisiana one-year statute of limitations should not, however, bar respondent's action here since retroactive application of that statute under Rodrigue would deprive respondent of any remedy at all on the basis of the unforeseeable superseding legal doctrine of that decision. Pp. 105-109.
5 Cir., 430 F.2d 27, affirmed.
Lloyd Cyril Melancon, New Orleans, La., for petitioner.
Samuel C. Gainsburgh, New Orleans, La., for respondent.
Mr. Justice STEWART delivered the opinion of the Court.