Fifth Circuit Applies Louisiana Oilfield Anti-Indemnity Act to Offshore Platform Service Contract, Rejecting Maritime Law Characterization

The Fifth Circuit held that a master service contract between an offshore platform owner and a labor provider was nonmaritime despite requiring vessel transportation, rendering the contract's indemnity provision unenforceable under Louisiana's Oilfield Anti-Indemnity Act. The court applied a two-part test focusing on whether vessels would play a substantial role in contract completion, finding that the contract's definition of work as 'Lease Operators' and the parties' expectations precluded maritime characterization under OCSLA.