The case concerned whether the Social Security Administration could offset overpayments of Supplemental Security Income (SSI) benefits made to the claimant's husband against her retroactive Title II disability benefits. The court decided to reverse the Commissioner's decision and remand the case for further proceedings. The core reasoning was that the relevant statute, 42 U.S.C. § 1320a-6, permits offsets only for benefits received by the same individual or spouse in the context of their own entitlements, not cross-spouse offsets, and that benefits at the couple rate must still be calculated separately for each spouse.
This case involved cross-motions for summary judgment in a declaratory judgment action arising from an offshore oil drilling contract between Sonat Exploration and Falcon Drilling. An employee of Sperry-Sun was injured on a rig operated by FDI, a Falcon affiliate, and FDI sought defense and indemnity from Sonat under the contract after being sued by the employee. Sonat argued it owed no such obligations and was instead entitled to coverage as an additional insured on Falcon's policy. The court granted Sonat's motion and denied FDI's, holding that the contract required Falcon to procure broad general liability insurance covering all parties' risks and contractual indemnities, with Sonat named as an additional insured, and that insurance coverage must be exhausted before any defense or indemnity obligations apply.
This case arose from injuries sustained by plaintiff Jerry B. Hodgen during a swing rope transfer from a fixed platform to a vessel in the Gulf of Mexico in 1991. The court had previously found defendants Forest Oil Corporation (as time charterer) and A & A Boats/C & G Marine negligent under general maritime law, awarding over $2.4 million in damages apportioned 85% to Forest and 15% to A & A/C & G, while ruling Forest was not at fault as platform owner. On remaining claims, the court denied Forest's request for defense costs from plaintiff's employer OCS under the Meloy exception to the Louisiana Oilfield Anti-Indemnity Act because Forest was found at fault overall as one entity. It also held that contractual provisions making Forest and A & A/C & G additional assureds under OCS's insurance policies were void under the Act absent evidence that Forest paid its share of premiums, and addressed related insurance priority and limitation-of-liability issues among the parties.
This case involves a personal injury claim by Jerry Hodgen, an employee of Operators and Consulting Services (OCS), who was hurt during a swing rope transfer from a fixed oil platform to a vessel in the Gulf of Mexico. The court had previously found negligence by Forest Oil (as time charterer) and the vessel owners, and the current ruling addresses Forest's indemnity claims against OCS and its insurers under a master service contract. On reconsideration, the court determined that the contract was non-maritime in nature because OCS's services were performed on fixed platforms rather than vessels. As a result, the Outer Continental Shelf Lands Act incorporated Louisiana's Oilfield Anti-Indemnity Act, which voids the contractual indemnity provisions to the extent they cover the indemnitee's own negligence. The court therefore dismissed the cross-claims and third-party demands for contractual indemnity.
The case involved a platform worker, Jerry Hodgen, who was injured while transferring by swing rope from an unmanned oil platform to a vessel in the Gulf of Mexico in May 1991. Hodgen, employed by OCS and working on platforms owned by Forest Oil (which time-chartered the vessel from A&A/C&G), sued for negligence under the Longshore and Harbor Workers' Compensation Act for the vessel-related claims and Louisiana law for the platform claims. After a bench trial, the court found Forest negligent as time-charterer for directing the transfer in rough seas of 7-9 feet when a helicopter was available, and A&A/C&G negligent for permitting the transfer without adequate safety procedures; platform claims were dismissed because Hodgen was a borrowed employee of Forest. The court awarded Hodgen over $2.4 million in damages for past and future medical expenses, lost wages, and pain and suffering, while rejecting his wife's loss of consortium claim.
This case concerns whether a material misrepresentation on an application for group health insurance under an ERISA-regulated employee benefit plan voids the policy even if made in good faith. On remand from the Fifth Circuit, which held that the relevant Louisiana statute was preempted by ERISA, the court applied federal common law and ruled in favor of the insurer, Pacific Mutual. The court held that under general contract principles, including Restatement (Second) of Contracts § 164, a misrepresentation that is material and induces issuance of the policy allows avoidance regardless of the applicant's intent or good faith. The decision emphasized ERISA's goal of uniform regulation and noted that requiring proof of fraud would increase insurer costs by necessitating more independent medical examinations.
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