Chevron USA Inc. v. Plaquemines Parish

Docket Number: 24-813
Citation: 608/1
Term: October Term 2025
Argued: January 12, 2026
Decided: April 17, 2026
Lower Court: United States Court of Appeals for the Fifth Circuit
Author: Associate Justice Clarence Thomas
Concurring: Clarence Thomas, John G. Roberts, Jr., Sonia Sotomayor, Elena Kagan, Neil M. Gorsuch, Brett M. Kavanaugh, Amy Coney Barrett, Ketanji Brown Jackson

AI-Generated Summary

Louisiana enacted the State and Local Coastal Resources Management Act in 1978, prohibiting oil production in the coastal zone without a permit effective 1980, but exempting uses legally commenced before then.
In 2013, Plaquemines Parish and other parishes filed 42 state-court suits against oil and gas companies, including Chevron, alleging lack of permits and that pre-1980 uses (including WWII-era crude-oil production in Plaquemines Parish fields like Delta Duck Club) were illegally commenced due to methods like earthen pits, vertical drilling, and canals.
During WWII, Chevron (via predecessor Texas Company) contracted with the U.S. Government to refine crude oil into aviation gasoline (avgas) for the military under Petroleum Administration for War (PAW) directives emphasizing rapid production increases; much Plaquemines crude supported this refining, using challenged methods to maximize output and conserve resources.
Chevron removed under 28 U.S.C. §1442(a)(1), claiming the suit related to its federal avgas refining duties; district court remanded to state court; Fifth Circuit affirmed, finding no relation as refining contract did not specify crude production methods; Supreme Court granted certiorari.

Whether the state-court suit challenging Chevron's WWII crude-oil production is "for or relating to" Chevron's acts under federal officers (avgas refining) for federal officer removal under 28 U.S.C. §1442(a)(1), which requires the defendant act under a federal officer, the suit relate to such acts, and a colorable federal defense.
Involves statutory interpretation of "relating to" (added in 2011), distinct from "acting under."
Chevron argued a close connection as crude was essential feedstock for avgas amid wartime urgency; Fifth Circuit and Louisiana countered no specific contract directive on production or "acting under" for challenged acts, severing relation via government allocation.

Author & Type: Justice Thomas, Majority opinion, joined by Roberts, C.J., Sotomayor, Kagan, Gorsuch, Kavanaugh, and Barrett, JJ.
Holding: Chevron plausibly alleged a close (not tenuous, remote, or peripheral) relationship between challenged WWII crude production and federal avgas refining duties, satisfying "relating to"; no need for federal duties to specifically require or strictly cause the conduct.
Legal Reasoning: "Relating to" broadly means "to stand in some relation; have bearing or concern" (Morales v. Trans World Airlines), encompassing indirect connections without strict causation (Ingersoll-Rand, Ford Motor Co.), but limited to non-attenuated links (Rutledge concurrence); here, challenged methods (vertical drilling, canals, pits) maximized wartime crude output—avgas feedstock—from critical fields, per PAW directives and contracts adjusting for crude costs, in "all-hands-on-deck" context; rejects Fifth Circuit's contract-specificity and allocation-severance rationales (relations persist via intermediaries, Morales); Louisiana's conflation of "acting under" and "relating to" renders latter redundant.
Disposition: Vacated Fifth Circuit judgment and remanded.

Justice Jackson, concurring in the judgment.
Agrees suit satisfies "for or relating to" but via causal nexus (federal duties as but-for cause of challenged conduct, per pre-2011 precedent like Willingham); 2011 "relating to" addition was conforming amendment to clarify removal of presuit discovery (not jettison causal test), per legislative history (H.R. Rep., hearings); Chevron meets nexus as crude production met avgas demands under federal contracts/PAW push.

Clarifies "relating to" in §1442(a)(1) demands close connection to federal duties without specific directives or strict causation, broadening removal for indirect but non-peripheral links (e.g., wartime supply chains); distinguishes from attenuated claims (e.g., modern climate suits); preserves "acting under" as separate element; applies crediting plausible removal allegations at remand stage (Dart Cherokee).

This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.

Key terms: Federal Court Removal, WWII Oil Production, Military Fuel Refining