Court Holds California Law Applies to Offshore Workers on Oil Platforms

Recently, a California Court of Appeal held that crew members on a ship that provided maintenance services to offshore oil platforms were governed by California’s wage payment laws.  The decision, in the case of Gulf Offshore Logistics v. Superior Court, held that the State’s laws applied to such employees because California served as the basis for their operations, even though they resided in other states and their employer was located in Louisiana.  Gulf Offshore Logistics, LLC v. Superior Court of Ventura Cty., WL 7137048 (Cal. Ct. App. Dec. 7, 2020).

After being hired in Louisiana, the crew members were transported by their employer to Port Hueneme, California, where they boarded a vessel named the Adele Elise for the purpose of delivering supplies and picking up refuse from four oil platforms located in federal waters accessed by the Santa Barbara Channel off the California coast.  The employees made an average of three trips each week to the platforms and worked a schedule of 42 days on and 21 days off, and would routinely return to their home states during their “off” periods.  The vessel was docked exclusively in Port Hueneme.

In reaching its decision, the Court first confirmed that California’s laws implicitly extend to employment occurring within the State’s boundaries, which are defined as including all of the Santa Barbara Channel.  The Court then stated that the test of whether California law applies to employees working in this State is whether their “principal place of work” is in California, which consists of “their base of work operations” regardless of their place of residence or that of their employer.  The Court held that California law governed the employment relationships at issue because California served as the base for the crew members’ work operations, even though they performed work on waters that were within the federal territorial boundaries.

The case is an important reminder to out-of-state employers that California law will likely apply to non-resident employees who perform most of their work within California.

Categories: Wage & Hour

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