In the case of Pacific Operators Offshore, LLP v. Luisa L. Valladolid et al., 2011, the U.S Supreme Court was tasked with determining whether an employee's injury occurring on land could be covered under the Outer Continental Shelf Lands Act (OCSLA). The OCSLA extends certain benefits to workers injured or killed as a result of operations conducted on the outer continental shelf for extracting natural resources. Juan Valladolid, an employee of Pacific Operators Offshore, died in a forklift accident at an on-shore facility and his widow filed for benefits under OCSLA which were initially denied because he wasn't working directly on offshore drilling platforms when he was killed. However, upon appeal to the Ninth Circuit court it ruled that if there is a "substantial nexus" between injury and extractive operations then compensation should be given regardless of location where incident occurred. This decision was appealed by Pacific Operators leading to this Supreme Court hearing which ultimately decided that coverage under OCSLA depends not just upon where but also how closely tied worker’s activities are to resource extraction from outer continental shelf.

In the dissenting opinion for Pacific Operators Offshore, LLP v. Valladolid, Justice Scalia disagreed with the majority's interpretation of the Outer Continental Shelf Lands Act (OCSLA). He argued that OCSLA should only apply to injuries occurring on the outer continental shelf itself and not extend to those happening elsewhere. According to him, Congress intended a geographical limitation when it enacted OCSLA; hence its benefits should not be extended beyond this boundary. The majority’s “substantial nexus” test was seen as an overreach by Justice Scalia because it allowed for claims even if they occurred off-site or were indirectly related to offshore operations. He believed this approach would lead to unnecessary litigation and uncertainty about which laws applied in certain situations involving offshore workers' compensation claims.