Background and Procedural History

Multiple Louisiana coastal parishes brought suit against Chevron and other oil and gas companies in state court under the State and Local Coastal Resources Management Act (SLCRMA), alleging the companies lacked required permits for their uses of the coastal zone. The parishes contended that certain pre-SLCRMA uses were not exempt from the Act's permitting requirements because they had been illegally commenced during World War II. The companies removed the actions to federal court under 28 U.S.C. § 1442(a)(1), the federal officer removal statute, asserting their operations related to contracts with the federal government to produce aviation gasoline for the military's war efforts during WWII. Both the Eastern and Western Districts of Louisiana granted the parishes' motions to remand, and the Fifth Circuit affirmed in a consolidated appeal. The Supreme Court granted certiorari.

The Federal Officer Removal Framework

The Supreme Court's analysis centered on the second prong of the three-part federal officer removal test: whether the suit was "for or relating to" an act under color of federal office. Justice Thomas wrote the opinion for the Court, joined by Chief Justice Roberts and Justices Sotomayor, Kagan, Gorsuch, Kavanaugh, and Barrett. The majority emphasized that the statutory phrase "relating to" sweeps broadly, meaning "to stand in some relation" to the federal duties. The Court clarified that one thing can relate to another "even if it was not specifically designed to affect it" and "even without a strict causal relationship." Rejecting a narrow construction, the Court held that a removing defendant need not show that federal duties specifically required or strictly caused the challenged conduct.

Application to WWII-Era Coastal Operations

The Court concluded that the company's crude oil production in Louisiana's coastal zone during World War II "related to" its performance under federal contracts to produce aviation gasoline. The parishes' SLCRMA suit alleged that the company's use of the coastal zone had been illegally commenced during WWII. The Court found the requisite nexus between the coastal zone operations and the federal contract performance. Significantly, the majority rejected the argument that the federal contract's silence on crude oil sourcing methods defeated removal jurisdiction. The Court held that the fact that the oil company's contract with the federal government during World War II for aviation gasoline refining did not specify how to obtain or produce crude oil used to create aviation gasoline did not render the company's crude oil production unrelated to performance of its duties under the contract.

Implications for Coastal Litigation and Federal Jurisdiction

The decision represents a significant expansion of federal officer removal jurisdiction in the context of historical environmental and coastal management claims. By adopting a broad interpretation of the "relating to" requirement, the Court has made it easier for defendants to remove state law claims to federal court when those claims challenge conduct connected to historical federal contracts, even when the contracts did not explicitly authorize the specific methods or practices at issue. Justice Jackson filed an opinion concurring in the judgment, and Justice Alito took no part in the decision. The case has been vacated and remanded for further proceedings consistent with the Supreme Court's opinion.