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Admiralty Law Keyed to Maraist
Gulf Offshore Co. v. Mobil Oil Corp.
Citation:
453 U.S. 473 (1981)Facts
Mobil Oil contracted with Gulf Offshore to perform completion operations on oil drilling platforms offshore of Louisiana, with Gulf promising to indemnify Mobil for all claims resulting from the work. In September 1975, Hurricane Eloise required evacuation of workers from oil platforms in the Gulf of Mexico. Steven Gaedecke, a Gulf Offshore employee working on a platform above the Outer Continental Shelf, was safely taken aboard a boat chartered by Mobil. While assisting with evacuation efforts in turbulent seas, Gaedecke was washed across the deck by a wave, suffering injuries primarily to his back. Gaedecke sued Mobil in Texas state court, and Mobil filed a third-party complaint for indemnification against Gulf Offshore. Gulf Offshore argued that the state court lacked jurisdiction because the case arose under OCSLA, which they claimed vested exclusive jurisdiction in federal courts. The trial court rejected this argument. Gulf Offshore also requested a jury instruction that personal injury damages are not subject to federal income taxation, which the court denied. The jury found Mobil negligent and awarded Gaedecke $900,000, determining that his injuries occurred while performing work subject to the indemnification contract, making Gulf Offshore liable for the damages.
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