Fifth Circuit Applies Louisiana Oilfield Anti-Indemnity Act to Offshore Platform Fire Watch Contract, Finding No Maritime Nexus

The Fifth Circuit affirmed that a master services contract between offshore platform operator Fieldwood Energy and safety contractor United Fire & Safety was nonmaritime in nature, triggering OCSLA's gap-filling provision to apply Louisiana's Oilfield Anti-Indemnity Act and void indemnity provisions in a personal injury action arising from a liftboat capsizing incident. The panel held that neither the contract nor job order email provided that the chartered liftboat would play a "substantial role" in completion of fire watch services on the fixed platform, despite the vessel's use for transportation, crane work, and lodging.