Parker Drilling Management Services, Ltd. v. Brian Newton (2019)
In Parker Drilling Management Services, Ltd. v. Brian Newton (2019), the Supreme Court ruled that a state’s labor laws do not apply to an offshore area under the control of the federal government.
The Outer Continental Shelf Lands Act (OCSLA) extends federal law to the subsoil and seabed of the Outer Continental Shelf (OCS). Under the OCSLA, all law on the OCS is federal law, and the states are not permitted any interest in or jurisdiction over the OCS. But because federal law in that area is not comprehensive enough to cover all aspects of human behavior, the OCSLA deems adjacent state’s laws to be federal law “to the extent that they are applicable and not inconsistent with” other federal law.
Brian Newton worked for Parker Drilling Management Services on an offshore drilling platform off the coast of California. Newton had 14-day shifts consisting of 12 hours on duty and 12 hours off duty. While he was off duty – on “standby” – Newton was not allowed to leave the platform. He was not paid for his time on standby.
Newton sued Parker, alleging that Parker’s refusal to pay him during standby violated several California labor laws, including the state’s minimum-wage law. The parties agreed that the OCSLA applied to the lawsuit, but they disagreed whether the California laws were “applicable and not inconsistent with” the federal law.
The Court began by pointing out that the OCSLA does not automatically extend all state law to the OCS. The Court noted that federal law is “exclusive” in the regulation of the OCS, and that state law is adopted only when necessary to fill in a gap in federal law. When a state law fills a gap, such laws are declared to be federal law, administered by federal officials. “The question,” the Court explained, “is whether federal law has already addressed the relevant issue; if so, state law addressing the same issue would necessarily be inconsistent with existing federal law and cannot be adopted as surrogate federal law.”
The Court compared the treatment of the OCS with federal enclaves (such as national parks). The Court pointed out that in such enclaves, state law does not continue in force to the extent that it conflicts with federal policy. This approach ensures that all areas will have a developed legal system for the protection of private rights while maintaining the supremacy of federal law.
In applying this analysis to Newton’s contention that California law should apply to his standby and minimum-wage claims, the Court held that the federal Fair Labor Standards Act already has applicable provisions for both claims. Thus, the Court rejected these claims because there was no gap that needed to be filled by state law.
Lance A. Cooper
Last updated: August 2019