Justia Summary
Newton worked on drilling platforms off the California coast. Newton was paid for his time on duty but not for his time on standby, during which he could not leave the platform. Newton filed a class action, alleging that California laws required compensation for standby time. The platforms were subject to the Outer Continental Shelf Lands Act (OCSLA), which provides that all law on the Outer Continental Shelf (OCS) is federal law; denies states any interest in or jurisdiction over the OCS; and deems the adjacent state’s laws to be federal law only “[t]o the extent that they are applicable and not inconsistent with” federal law, 43 U.S.C. 1333(a)(2)(A).
A unanimous Supreme Court vacated a Ninth Circuit decision in favor of Newton. Where federal law addresses the relevant issue, state law is not adopted as surrogate federal law on the OCS. The Court rejected Newton’s proposed pre-emption analysis; federal law is the only law on the OCS and there is no overlapping state and federal jurisdiction, so the reference to “not inconsistent” state laws presents only the question whether federal law has already addressed the issue. If so, state law on the issue is inapplicable. Some of Newton’s claims are premised on California law requiring payment for all standby time but federal law already addresses that issue. To the extent his OCS-based claims rely on California’s minimum wage, the Fair Labor Standards Act already provides for a minimum wage.