Opinion Summary: Chevron v. Plaquemines | WWII Avgas Flies Chevron's Case to Federal Court

Chevron USA Inc. v. Plaquemines Parish | Case No. 24-813 | Decided: April 17, 2026 | Docket Link: Here

Question Presented: Whether a state environmental lawsuit challenging a WWII military contractor's crude oil production "relates to" its federal avgas refining contract under the federal officer removal statute.

Overview: Louisiana parishes sued Chevron over World War II oil production damage. Chevron invoked the federal officer removal statute, arguing its wartime crude oil production closely related to its military contract to refine aviation gasoline for the U.S. military.

Posture: District Court and Fifth Circuit both denied removal; Supreme Court granted certiorari.

Holding: Chevron plausibly alleged a close relationship between its challenged crude-oil production and the performance of its federal aviation gas refining duties and therefore satisfied the “relating to” requirement of the federal officer removal statute.

Voting Breakdown: 8-0. Justice Thomas authored the majority, joined by six Justices. Justice Jackson authored an opinion concurring in the judgment. Justice Alito did not participate in the case.

Result: Vacated and remanded.

Majority Reasoning: (1) "Relating to" under the federal officer removal statute requires a close — not tenuous, remote, or peripheral — connection between challenged conduct and federal duties; no explicit contractual directive needed; (2) Chevron's crude oil production closely related to its federal avgas refining — wartime drilling practices directly enabled military fuel output; (3) The P.A.W.'s role allocating crude oil among refineries as an intermediary did not sever the production-refining relationship.

Separate Opinions:

• Justice Jackson (concurring in judgment): Agreed Chevron satisfies the removal requirements but argued the 2011 "or relating to" amendment preserved the prior causal-nexus test rather than replacing it with a looser indirect-relationship standard; Chevron satisfies both tests.

Implications: Military contractors and other companies that performed federal government work during wartime now carry stronger arguments to move state environmental and other lawsuits into federal court. The ruling clarifies that a close relationship between challenged conduct and federal duties suffices — no explicit contractual directive required. Jackson's concurrence signals future courts may apply a stricter causal-nexus test when facts run thinner. Louisiana parishes pursuing decades-old coastal damage claims against other wartime oil companies face the same federal-forum question across 41 remaining lawsuits.

The Fine Print:

• 28 U.S.C. §1442(a)(1): "[A] civil action or criminal prosecution that is commenced in a State court and that is against or directed to . . . [t]he United States or any agency thereof or any officer (or any person acting under that officer) of the United States or of any agency thereof . . . for or relating to any act under color of such office."
• Louisiana Coastal Resources Management Act, La. Rev. Stat. Ann. §49:214.34(C)(2): "Individual specific uses legally commenced or established prior to the effective date of the coastal use permit program."

Primary Cases:

• Morales v. Trans World Airlines, Inc. (1992): "Relating to" encompasses indirect connections; state advertising rules related to airline rates even where consumer decisions intervened as intermediaries in the causal chain.
• Ingersoll-Rand Co. v. McClendon (1990): A law "relates to" something even when lawmakers never specifically designed it to affect that subject; explicit direction unnecessary to establish a cognizable relationship.