Case Law Parker Drilling Mgmt. Servs., Ltd. v. Newton

Parker Drilling Mgmt. Servs., Ltd. v. Newton

Document Cited Authorities (35) Cited in (58) Related (1)

Paul D. Clement, Washington, DC, for the petitioner.

Christopher G. Michel, for the United States as amicus curiae, by special leave of the Court, in support of the petitioner.

David C. Frederick, Washington, DC, for the respondent.

Ronald J. Holland, Ellen M. Bronchetti, McDermott Will &, Emery LLP, Menlo Park, CA, Paul D. Clement, George W. Hicks, Jr., Michael D. Lieberman, Laura Wolk, Kirkland & Ellis LLP, Washington, DC, for petitioner.

Michael A. Strauss, Aris E. Karakalos, Strauss & Strauss APC, Ventura, CA, Erin Glenn Busby, Lisa R. Eskow, Michael F. Sturley, Austin, TX, David C. Frederick, Ana Nikolic, Kellogg, Hansen, Todd, Figel & Frederick, P.L.L.C., Washington, DC, for respondent.

Justice THOMAS delivered the opinion of the 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. § 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. Applying familiar tools of statutory interpretation, we hold that where federal law addresses the relevant issue, state law is not adopted as surrogate federal law on the OCS.

I

Respondent Brian Newton worked for petitioner Parker Drilling Management Services on drilling platforms off the coast of California. Newton’s 14-day shifts involved 12 hours per day on duty and 12 hours per day on standby, during which he could not leave the platform. He was paid well above the California and federal minimum wages for his time on duty, but he was not paid for his standby time.

Newton filed a class action in California state court alleging violations of several California wage-and-hour laws and related state-law claims. Among other things, Newton claimed that California’s minimum-wage and overtime laws required Parker to compensate him for the time he spent on standby. Parker removed the action to Federal District Court. The parties agreed that Parker’s platforms were subject to the OCSLA. Their disagreement centered on whether the relevant California laws were "applicable and not inconsistent" with existing federal law and thus deemed to be the applicable federal law under the OCSLA. § 1333(a)(2)(A).

The District Court applied Fifth Circuit precedent providing that under the OCSLA, "state law only applies to the extent it is necessary ‘to fill a significant void or gap’ in federal law." App. to Pet. for Cert. 51 (quoting Continental Oil Co. v. London Steam-Ship Owners’ Mut. Ins. Assn. , 417 F. 2d 1030, 1036 (1969) ). It determined that the Fair Labor Standards Act of 1938 (FLSA), 52 Stat. 1060, 29 U.S.C. § 201 et seq. , constitutes a comprehensive federal wage-and-hour scheme and thus left no significant gap for state law to fill. Because all of Newton’s claims relied on state law, the court granted Parker judgment on the pleadings.

The Ninth Circuit vacated and remanded. It first held that state law is " ‘applicable’ " under the OCSLA whenever it "pertain[s] to the subject matter at hand." 881 F. 3d 1078, 1090, amended and reh’g en banc denied, 888 F. 3d 1085 (2018). The court found that California wage-and-hour laws satisfied this standard and turned to "the determinative question in Newton’s case": "whether California wage and hour laws are ‘inconsistent with’ existing federal law." 881 F. 3d at 1093. According to the Ninth Circuit, state laws are "inconsistent" with federal law under the OCSLA only "if they are mutually incompatible, incongruous, [or] inharmonious." Ibid. (internal quotation marks omitted). Applying that standard, the court determined that no inconsistency exists between the FLSA and California wage-and-hour law because the FLSA saving clause "explicitly permits more protective state wage and hour laws." Id. , at 1097 (citing 29 U.S.C. § 218(a) ). Given the disagreement between the Fifth and Ninth Circuits, we granted certiorari. 586 U. S. ––––, 139 S.Ct. 914, 202 L.Ed.2d 641 (2019).

II

Before the OCSLA, coastal States and the Federal Government disputed who had the right to lease submerged lands on the continental shelf. Some coastal States even asserted jurisdiction all the way to the outer edge of the shelf. See Shell Oil Co. v. Iowa Dept. of Revenue , 488 U. S. 19, 26, 109 S.Ct. 278, 102 L.Ed.2d 186 (1988). The disputes eventually reached this Court, which held in a series of decisions that the Federal Government has exclusive jurisdiction over the entire continental shelf. See United States v. California , 332 U. S. 19, 38–39, 67 S.Ct. 1658, 91 L.Ed. 1889 (1947) ; United States v. Louisiana , 339 U. S. 699, 705, 70 S.Ct. 914, 94 L.Ed. 1216 (1950) ; United States v. Texas , 339 U. S. 707, 717–718, 70 S.Ct. 918, 94 L.Ed. 1221 (1950).

After these decisions, Congress divided jurisdiction over the shelf. In 1953, Congress enacted the Submerged Lands Act, 67 Stat. 29, 43 U.S.C. § 1301 et seq. , which ceded to the coastal States offshore lands within a specified distance of their coasts. A few months later, Congress passed the OCSLA, which affirmed that the Federal Government exercised exclusive control over the OCS, defined as "all submerged lands" beyond the lands reserved to the States up to the edge of the United States’ jurisdiction and control. § 1331(a). Specifically, the OCSLA declares that "the subsoil and seabed of the [OCS] appertain to the United States and are subject to its jurisdiction, control, and power of disposition." § 1332(1). The OCSLA then sets forth "detailed provisions for the exercise of exclusive jurisdiction in the area and for the leasing and development of the resources of the seabed." United States v. Maine , 420 U. S. 515, 527, 95 S.Ct. 1155, 43 L.Ed.2d 363 (1975) ; see §§ 1334–1354.

Of primary relevance here, the OCSLA defines the body of law that governs the OCS. First, in § 1333(a)(1), the OCSLA extends "[t]he Constitution and laws and civil and political jurisdiction of the United States" to the OCS. Section 1333(a)(1) provides that federal law applies "to the same extent as if the [OCS] were an area of exclusive Federal jurisdiction located within a State." Then, § 1333(a)(2)(A) provides:

"To the extent that they are applicable and not inconsistent with this subchapter or with other Federal laws and regulations of the Secretary now in effect or hereafter adopted, the civil and criminal laws of each adjacent State, now in effect or hereafter adopted, amended, or repealed are declared to be the law of the United States for that portion of the subsoil and seabed of the outer Continental Shelf, and artificial islands and fixed structures erected thereon, which would be within the area of the State if its boundaries were extended seaward to the outer margin of the outer Continental Shelf ...."

Section 1333(a)(2)(A) also states that "[a]ll of such applicable laws shall be administered and enforced by the appropriate officers and courts of the United States." Finally, § 1333(a)(3) emphasizes that "[t]he provisions of this section for adoption of State law as the law of the United States shall never be interpreted as a basis for claiming any interest in or jurisdiction on behalf of any State for any purpose over" the OCS.

III
A

The question in this case is how to interpret the OCSLA’s command that state laws be adopted as federal law on the OCS "[t]o the extent that they are applicable and not inconsistent" with other federal law. § 1333(a)(2)(A). Echoing the Ninth Circuit, Newton argues that state law is "applicable" on the OCS whenever it pertains to the subject matter at issue. Newton further argues that state law is only "inconsistent" with federal law if it is incompatible with the federal scheme. In essence, Newton’s argument is that state law is "inconsistent" only if it would be pre-empted under our ordinary pre-emption principles.

Parker, on the other hand, argues that state law is not "applicable" on the OCS in the absence of a gap in federal law that needs to be filled. Moreover, Parker argues that state law can be "inconsistent" with federal law even if it is possible for a party to satisfy both sets of laws. Specifically, Parker contends that, although the FLSA normally accommodates more protective state wage-and-hour laws, such laws are inconsistent with the FLSA when adopting state law as surrogate federal law because federal law would then contain two different standards.

B

Although this is a close question of statutory interpretation, on the whole we find Parker’s approach more persuasive because " ‘the words of a statute must be read 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, 132 S.Ct. 1350, 182 L.Ed.2d 341 (2012). That rule is particularly relevant here, as the terms "applicable" and "not inconsistent" are susceptible of interpretations that would deprive one term or the other of meaning. If Newton is right that "applicable" merely means relevant to the subject matter, then the word adds nothing to the statute, for an irrelevant law would never be "applicable" in that sense. Cf. Ransom v. FIA Card Services, N. A. , 562 U. S. 61, 70, 131 S.Ct. 716, 178 L.Ed.2d 603 (2011) (declining to interpret the word "applicable" in such a way that Congress "could have omitted the term ... altogether"). And if Parker is right that "applicable" means "necessary to fill a gap in federal law," it is hard to imagine circumstances in which "not...

5 cases
Document | U.S. District Court — District of Maine – 2020
United States v. Manubolu, 1:19-cr-00184-JAW
"... ... at 2-3 (citing Parker Drilling Mgmt. Servs., Ltd. v. Newton , ... "
Document | U.S. District Court — Southern District of California – 2021
Vestavia Hills, Ltd. v. U.S. Small Bus. Admin. (In re Hills)
"... ... Sea-Land Servs., Inc. , 566 U.S. 93, 101, 132 S.Ct. 1350, 182 L.Ed.2d 341 ... 2020) (quoting Parker" Drilling Mgmt. Servs., Ltd. v. Newton , ––– U.S. –\xE2" ... "
Document | U.S. District Court — District of New Jersey – 2021
City of Hoboken v. Exxon Mobil Corp.
"... ... v. Allapattah Servs., Inc. , 545 U.S. 546, 552, 125 S.Ct. 2611, 162 ... Shelf and all attachments thereon." Parker Drilling Mgmt. Servs., Ltd. v. Newton , ... "
Document | U.S. Court of Appeals — Third Circuit – 2022
FDRLST Media, LLC v. Nat'l Labor Relations Bd.
"... ... Labor Mgmt. Relations Act, ch. 120, sec. 101, § 10(b), 61 ... PNC Fin. Servs. Grp., Inc. , 477 F.3d 56, 67 (3d Cir. 2007) ... Cent. Ltd. v. United States , ––– U.S. ––––, ... place in the overall statutory scheme," Parker Drilling Mgmt. Servs., Ltd. v. Newton , ... "
Document | U.S. Court of Appeals — Eleventh Circuit – 2022
United States v. Garcon
"... ... Cent. Ltd v. United States , ––– U.S. ––––, ... U.S. Bureau of Citizenship & Immigr. Servs., 701 F.3d 356, 364 (11th Cir. 2012). And ... 441 (quotations omitted); see also Parker Drilling Mgmt. Servs. , Ltd. v. Newton , ... "

Try vLex and Vincent AI for free

Start a free trial
5 books and journal articles
Document | Vol. 132 Núm. 5, March 2023 – 2023
Reviving the Prophylactic VRA: Section 3, Purcell, and the New Vote Denial.
"...statutory interpretation that 'Congress legislates against the backdrop of existing law.'" Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881, 1890 (2019) (quoting McQuiggin v. Perkins, 569 U.S. 383, 398 n.3 (202.) See Hernandez v. New York, 500 U.S. 352, 371-72 (1991) (plurality..."
Document | Núm. 71-4, 2022
Patching the Holes in Sox: Fcpa Disgorgement After Liu and the Ndaa
"...that courts must give effect, if possible, to every clause and word of a statute" (quoting Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881, 1890 (2019))).169. See Nick Oberheiden, 10 Reasons Why FCPA Compliance Is Critically Important for Businesses, Nat'l L. Rev. (July 24, 20..."
Document | Vol. 20 Núm. 1, December 2020 – 2020
Offshore Windfarms: What Laws Apply?
"...352, 365 (1969) (deciding maritime laws are ill adapted to deal with artificial islands); see Parker Drilling Mgmt. Servs. v. Newton, 139 S. Ct. 1881 (2019) (stating that the OCSLA gives the Federal Government complete jurisdiction, control, and power of disposition over the OCS, while givi..."
Document | Vol. 52 Núm. 3, June 2022 – 2022
(Overview).
"...to the Ninth Circuit for a final ruling. (311) 43 U.S.C. [section] 1333(a)(2)(A). (312) Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881 (313) Black Lung Benefits Act (BLBA), 30 U.S.C. [section][section] 901-944 (2018). (314) Id. (315) Id."[section] 921(c)(4). (316) 5 U.S.C. [s..."
Document | Núm. 33-5, September 2019
Wage and Hour Case Notes
"...Who Work on the Outer Continental Shelf Are Not Subject to California Wage and Hour Law Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881 (2019) An employee who worked on a drilling platform on the Outer Continental Shelf (OCS) off the California coast brought a putative class a..."

Try vLex and Vincent AI for free

Start a free trial
1 firm's commentaries
Document | JD Supra United States – 2019
Ninth Circuit Dismisses California Wage Claims By Oil Rig Workers, Following High Court Ruling
"...v. Newton, 139 S. Ct. 1881, 204 L. Ed. 2d 165 (2019) on the Jackson Lewis publications page. Allyson Ascher Parker Drilling Mgmt. Servs. v. Newton, 139 S. Ct. 1881 (2019). In that case, the Supreme Court determined that workers on oil drilling platforms off the coast of California are cover..."

Try vLex and Vincent AI for free

Start a free trial

Experience vLex's unparalleled legal AI

Access millions of documents and let Vincent AI power your research, drafting, and document analysis — all in one platform.

Start a free trial

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex
5 books and journal articles
Document | Vol. 132 Núm. 5, March 2023 – 2023
Reviving the Prophylactic VRA: Section 3, Purcell, and the New Vote Denial.
"...statutory interpretation that 'Congress legislates against the backdrop of existing law.'" Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881, 1890 (2019) (quoting McQuiggin v. Perkins, 569 U.S. 383, 398 n.3 (202.) See Hernandez v. New York, 500 U.S. 352, 371-72 (1991) (plurality..."
Document | Núm. 71-4, 2022
Patching the Holes in Sox: Fcpa Disgorgement After Liu and the Ndaa
"...that courts must give effect, if possible, to every clause and word of a statute" (quoting Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881, 1890 (2019))).169. See Nick Oberheiden, 10 Reasons Why FCPA Compliance Is Critically Important for Businesses, Nat'l L. Rev. (July 24, 20..."
Document | Vol. 20 Núm. 1, December 2020 – 2020
Offshore Windfarms: What Laws Apply?
"...352, 365 (1969) (deciding maritime laws are ill adapted to deal with artificial islands); see Parker Drilling Mgmt. Servs. v. Newton, 139 S. Ct. 1881 (2019) (stating that the OCSLA gives the Federal Government complete jurisdiction, control, and power of disposition over the OCS, while givi..."
Document | Vol. 52 Núm. 3, June 2022 – 2022
(Overview).
"...to the Ninth Circuit for a final ruling. (311) 43 U.S.C. [section] 1333(a)(2)(A). (312) Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881 (313) Black Lung Benefits Act (BLBA), 30 U.S.C. [section][section] 901-944 (2018). (314) Id. (315) Id."[section] 921(c)(4). (316) 5 U.S.C. [s..."
Document | Núm. 33-5, September 2019
Wage and Hour Case Notes
"...Who Work on the Outer Continental Shelf Are Not Subject to California Wage and Hour Law Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881 (2019) An employee who worked on a drilling platform on the Outer Continental Shelf (OCS) off the California coast brought a putative class a..."

Try vLex and Vincent AI for free

Start a free trial

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex
5 cases
Document | U.S. District Court — District of Maine – 2020
United States v. Manubolu, 1:19-cr-00184-JAW
"... ... at 2-3 (citing Parker Drilling Mgmt. Servs., Ltd. v. Newton , ... "
Document | U.S. District Court — Southern District of California – 2021
Vestavia Hills, Ltd. v. U.S. Small Bus. Admin. (In re Hills)
"... ... Sea-Land Servs., Inc. , 566 U.S. 93, 101, 132 S.Ct. 1350, 182 L.Ed.2d 341 ... 2020) (quoting Parker" Drilling Mgmt. Servs., Ltd. v. Newton , ––– U.S. –\xE2" ... "
Document | U.S. District Court — District of New Jersey – 2021
City of Hoboken v. Exxon Mobil Corp.
"... ... v. Allapattah Servs., Inc. , 545 U.S. 546, 552, 125 S.Ct. 2611, 162 ... Shelf and all attachments thereon." Parker Drilling Mgmt. Servs., Ltd. v. Newton , ... "
Document | U.S. Court of Appeals — Third Circuit – 2022
FDRLST Media, LLC v. Nat'l Labor Relations Bd.
"... ... Labor Mgmt. Relations Act, ch. 120, sec. 101, § 10(b), 61 ... PNC Fin. Servs. Grp., Inc. , 477 F.3d 56, 67 (3d Cir. 2007) ... Cent. Ltd. v. United States , ––– U.S. ––––, ... place in the overall statutory scheme," Parker Drilling Mgmt. Servs., Ltd. v. Newton , ... "
Document | U.S. Court of Appeals — Eleventh Circuit – 2022
United States v. Garcon
"... ... Cent. Ltd v. United States , ––– U.S. ––––, ... U.S. Bureau of Citizenship & Immigr. Servs., 701 F.3d 356, 364 (11th Cir. 2012). And ... 441 (quotations omitted); see also Parker Drilling Mgmt. Servs. , Ltd. v. Newton , ... "

Try vLex and Vincent AI for free

Start a free trial

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex
1 firm's commentaries
Document | JD Supra United States – 2019
Ninth Circuit Dismisses California Wage Claims By Oil Rig Workers, Following High Court Ruling
"...v. Newton, 139 S. Ct. 1881, 204 L. Ed. 2d 165 (2019) on the Jackson Lewis publications page. Allyson Ascher Parker Drilling Mgmt. Servs. v. Newton, 139 S. Ct. 1881 (2019). In that case, the Supreme Court determined that workers on oil drilling platforms off the coast of California are cover..."

Try vLex and Vincent AI for free

Start a free trial