Chevron USA Inc. v. Plaquemines Parish

Majority — Thomas

Joined by: Roberts, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett

The majority held that the phrase "relating to" in the federal officer removal statute — a law that lets cases against federal officers or their contractors be moved from state to federal court — has a broad but not unlimited meaning: it requires a real connection, not a distant or trivial one. The Court reasoned that Chevron's crude-oil production in Plaquemines Parish was closely tied to its federal duty to refine that oil into aviation gasoline for the military, because much of the crude oil produced there fed directly into Chevron's own avgas refining, the government identified the specific oil field as critical to the war effort, and wartime regulations actually required the very drilling methods the parish now challenges. The majority rejected the Fifth Circuit's conclusion that the federal contract had to specifically direct or invite the crude-oil production for a "relating to" connection to exist, finding that standard too narrow. The majority also rejected the argument that the government's role in allocating crude oil between producers and refiners broke the connection, reasoning that an act can relate to its consequences even when an intermediary is involved. Finally, the Court rejected Louisiana's argument that Chevron had to be "acting under" a federal officer specifically when producing crude oil — holding that reading would make the "relating to" language in the statute meaningless.

Dissent reasoning

Justice Jackson agreed with the outcome — that the lawsuit should be removable to federal court — but disagreed with the majority's legal reasoning. In her view, the majority's interpretation of "relating to" sets the bar too low by allowing removal based on any indirect relationship between the challenged conduct and federal duties. She argued that courts should look to what Congress actually intended when it added "or relating to" to the statute in 2011, and that the legislative history makes clear Congress did not intend to change the existing legal standard, which required a causal connection — meaning the federal duty had to be a but-for cause of the challenged conduct. She explained that the 2011 addition was a minor "conforming amendment" meant only to confirm that pre-lawsuit discovery proceedings (like subpoenas) targeting federal officers could also be removed to federal court, not to loosen the causal-nexus standard for ordinary lawsuits. Because Chevron's crude-oil production was driven at least in part by the demands of its federal avgas contract, she concluded Chevron satisfied even the stricter causal-nexus test — and that the Fifth Circuit was wrong to demand a specific contractual directive pointing to oil production.