Parker Drilling Management Services, Ltd.v.Newton
Brian Newton worked on offshore drilling platforms and sought unpaid standby wages under California minimum-wage and overtime laws. The platforms were subject to the Outer Continental Shelf Lands Act, which adopts state law as federal law only when it is applicable and not inconsistent with federal law. The district court held that the federal Fair Labor Standards Act left no gap for California law to fill, while the Ninth Circuit treated state law as applicable whenever it addressed the subject matter. The Supreme Court vacated and remanded. It held that when federal law addresses the relevant issue, state law is not adopted as surrogate federal law on the outer continental shelf. The Fair Labor Standards Act addresses minimum wages and therefore prevents California’s minimum-wage law from applying through the Outer Continental Shelf Lands Act. The Court did not finally resolve every claim or whether Parker was entitled to judgment on the pleadings, so further proceedings remained necessary. The decision clarifies the relationship between federal offshore jurisdiction, surrogate state law, and a comprehensive federal wage scheme.
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