CHEVRON OIL CO. v. HUSON

Print this Page
Case Basics
Docket No. 
70-11
Petitioner 
Chevron Oil Co.
Respondent 
Gaines Ted Huson
Opinion 
Advocates
(for the respondent)
Tags
Term:
Facts of the Case 

Gaines Ted Huson suffered a back injury while working on a fixed oil rig, owned by Chevron Oil Company, off the coast of Louisiana. More than two years after the injury, Huson sued Chevron for damages in United States District Court, Eastern District of Louisiana, New Orleans Division. Huson alleged that it took several months for him to realize the severity of his injury. The District Court relied on Rodrigue v Aetna Casualty & Surety Co., 395 U.S. 352 (1969), holding that Louisiana’s one-year statute of limitations applied instead of the admiralty laches doctrine so Huson’s claim was barred. Rodrigue held that state law, not admiralty law, applied in these situations under the Outer Continental Shelf Lands Act. On appeal to the United States Court of Appeals for the Fifth Circuit, Huson argued that because he filed this case before the Rodrigue decision, applying its ruling would have an unfair retrospective effect. The Court of Appeals reversed, holding that the Louisiana statute of limitations was inconsistent with the admiralty laches doctrine and, therefore, was not applicable.

Question 

Is Louisiana statute of limitations inconsistent with the admiralty laches doctrine? Should Rogrique be retroactively applied?

Conclusion 
Decision: 7 votes for Huson, 0 vote(s) against
Legal provision: 43 U.S.C. 1331

No, No. In a 7-0 decision, Justice Potter Stewart, writing for a majority unanimous court, affirmed the Appeals Court’s decision, but rejected their analysis. The Supreme Court held that Louisiana’s statute of limitations was applicable under the Outer Continental Shelf Lands Act because the Lands Act specifically adopted relevant state laws as federal laws. There was no federal statute of limitations specified in the Lands Act so, state law was not inconsistent. Although applying Louisiana’s one-year statute of limitations was proper as a general rule, the Court held that applying it in this case would unfairly deprive Huson of a remedy on the basis of an unforeseeable change in legal doctrine.

Cite this Page
CHEVRON OIL CO. v. HUSON. The Oyez Project at IIT Chicago-Kent College of Law. 23 October 2014. <http://www.oyez.org/cases/1970-1979/1971/1971_70_11>.
CHEVRON OIL CO. v. HUSON, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1970-1979/1971/1971_70_11 (last visited October 23, 2014).
"CHEVRON OIL CO. v. HUSON," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 23, 2014, http://www.oyez.org/cases/1970-1979/1971/1971_70_11.