Chevron Oil Co. v. Huson

Summary

The Supreme Court held that the Outer Continental Shelf Lands Act requires application of the adjacent state's statute of limitations to personal-injury actions, rather than the admiralty doctrine of laches. It nevertheless affirmed the judgment remanding the case because the Louisiana one-year limitation, as required by Rodrigue v. Aetna Casualty & Surety Co., should not be applied retroactively to this pre-Rodrigue case. Justice Douglas concurred in the judgment but disagreed with the Court's reasoning.

Holdings

1. Under the Outer Continental Shelf Lands Act as interpreted in Rodrigue, Louisiana's one-year statute of limitations applies to a personal-injury action arising on a fixed structure on the Outer Continental Shelf.
2. The Louisiana one-year statute of limitations, although applicable under Rodrigue, should not be applied retroactively to bar Huson's pre-Rodrigue action.

Questions Presented

1. Whether the Outer Continental Shelf Lands Act requires application of the adjacent state's statute of limitations to a personal-injury action arising from an injury on a fixed structure on the Outer Continental Shelf.
2. Whether Rodrigue v. Aetna Casualty & Surety Co. should be applied retroactively to require application of Louisiana's one-year limitation period and thereby bar Huson's action.

Disposition

affirmed