Federal-Officer Removal: “Relating To” Requires a Close Wartime-Contract Connection, Not Contractual Specificity

I. Introduction

Chevron USA Inc. v. Plaquemines Parish (608 U. S. ___ (2026)) addresses the scope of the federal officer removal statute, 28 U. S. C. §1442(a)(1), in the context of Louisiana coastal-zone litigation. Plaquemines Parish and other Louisiana parishes brought state-court suits under Louisiana’s State and Local Coastal Resources Management Act, alleging that certain historical oil-and-gas activities lacked permits and that some pre-1980 activities were “illegally commenced” and therefore not covered by the Act’s grandfathering provision.

The dispute in this case turned on whether a parish suit challenging Chevron’s Second World War-era crude-oil production in Plaquemines Parish was removable to federal court because it was “for or relating to” Chevron’s wartime performance of federal duties—namely, refining crude oil into aviation gasoline (“avgas”) for the U. S. military under federal contracts. The Fifth Circuit accepted that Chevron “acted under” federal officers as a military contractor, but held the parish’s suit did not sufficiently relate to those federal duties. The Supreme Court vacated and remanded.

II. Summary of the Opinion

Justice Thomas, writing for the Court, held that Chevron plausibly alleged a close relationship between: (1) the parish’s challenged conduct (wartime crude-oil production practices such as vertical drilling, canals, and earthen pits), and (2) Chevron’s federal duties (wartime avgas refining for the military). A removing defendant need not show that federal duties specifically required the challenged conduct or that there is a strict causal relationship; but the connection must be more than “tenuous, remote, or peripheral.”

The Court rejected two principal Fifth Circuit rationales: (i) that Chevron’s refining contract did not specify how to acquire crude oil, and (ii) that the Government’s wartime allocation of crude oil to refineries severed the relationship between production and refining. The Court also rejected Louisiana’s alternative argument that removal requires Chevron to have been “acting under” a federal officer in performing the specific acts challenged in the complaint—an interpretation that would collapse the statute’s distinct elements and render “relating to” largely redundant.

Justice Jackson concurred only in the judgment, arguing that the 2011 addition of “or relating to” was a “conforming amendment” aimed at clarifying removability of presuit discovery proceedings, not eliminating the traditional causal-nexus requirement. She nonetheless concluded that, even under a causal-nexus test, Chevron satisfied §1442(a)(1) on these facts.

III. Analysis

A. Precedents Cited

1. The purpose and structure of federal officer removal

Watson v. Philip Morris Cos., 551 U. S. 142 (2007): Used for the modern understanding that §1442 protects the Federal Government from state-court “interference with its operations” and that private parties may qualify as persons “acting under” federal officers. Here, Watson framed the statute’s function and supported the Fifth Circuit’s (undisputed) conclusion that Chevron acted under federal officers as a wartime contractor.
Tennessee v. Davis, 100 U. S. 257 (1880): Cited for historical lineage (from the Force Bill of 1833) and the long-standing federal interest in a federal forum for federal-officer-related litigation. The citation reinforces a broad, protective orientation toward removal where federal operations are implicated.
Mesa v. California, 489 U. S. 121 (1989): Supplies the third requirement of the removal test—a “colorable federal defense”—and ties it to Article III limits. Although not litigated here, Mesa’s presence underscores that “relating to” is only one element in a multi-part gatekeeping framework.

2. Interpreting “relating to”: breadth with limits

Morales v. Trans World Airlines, Inc., 504 U. S. 374 (1992): The Court’s anchor for the broad semantic sweep of “relating to” (to “stand in some relation; to have bearing or concern”). Morales also supports the key rebuttal to the Fifth Circuit’s “intermediary” theory: an act may “relate to” an outcome even if the causal chain includes third-party actions (there, consumers; here, the P.A.W. allocating crude oil).
Ingersoll-Rand Co. v. McClendon, 498 U. S. 133 (1990): Cited for the proposition that “relating to” encompasses indirect connections and does not require that the challenged action be “specifically designed” to affect the relevant subject. The Court uses this preemption-context logic to reject the idea that Chevron’s contract had to expressly direct crude-oil production.
Ford Motor Co. v. Montana Eighth Judicial Dist. Court, 592 U. S. 351 (2021): Used for the point that “relating to” does not require a “strict causal relationship.” This is important because the Court’s standard is expressly not but-for causation.
Altria Group, Inc. v. Good, 555 U. S. 70 (2008): Cited in tandem with the above to reinforce that “relating to” does not demand strict causation.

3. Rejecting limitless “everything is related” readings

Rutledge v. Pharmaceutical Care Management Assn., 592 U. S. 80 (2020) (THOMAS, J., concurring): Supplies the limiting principle that ordinary meaning is not so broad as to become meaningless; the connection must not be “tenuous, remote, or peripheral.” This concurrence effectively becomes the majority’s boundary condition for §1442’s “relating to.”
California Div. of Labor Standards Enforcement v. Dillingham Constr., N. A., Inc., 519 U. S. 316 (1997) (Scalia, J., concurring): Quoted for the caution that literalist readings make everything related to everything else; supports the Court’s insistence on ordinary (not maximal) breadth.

4. Procedural posture and “plausible allegations” at removal

Dart Cherokee Basin Operating Co. v. Owens, 574 U. S. 81 (2014): Invoked for the idea that at this stage, courts credit the removing party’s plausible factual allegations. This matters because the Court repeatedly frames Chevron’s showing as “plausible” (e.g., that much crude oil from the field was used in its own avgas refining and that challenged practices increased wartime production).

5. Lower-court examples delimiting “relating to” in modern climate/energy litigation

District of Columbia v. Exxon Mobil Corp., 89 F. 4th 144 (CADC 2023): Cited as an example where modern false-advertising climate claims were held not to relate to decades-earlier government production—illustrating the “tenuous, remote, or peripheral” exclusion.
Minnesota v. American Petroleum Inst., 63 F. 4th 703 (CA8 2023): Cited in accord with the D.C. Circuit approach, reinforcing that not all climate-adjacent suits are removable under §1442.

6. The 2011 amendment context and the concurring debate over “causal nexus”

Jefferson County v. Acker, 527 U. S. 423 (1999): Cited (in a footnote) for the pre-2011 “for” language requiring a “nexus” or “causal connection,” highlighting what Congress arguably altered (majority) or did not alter (Jackson concurrence) when adding “or relating to.”
Willingham v. Morgan, 395 U. S. 402 (1969), and Maryland v. Soper, 270 U. S. 9 (1926): In Justice Jackson’s concurrence, these define the historical causal-nexus approach to federal officer removal and inform her view that Congress did not silently abandon it.
Learning Resources, Inc. v. Trump, 607 U. S. ___ (2026) (J ACKSON, J., concurring in part and concurring in judgment), and United States v. Hansen, 599 U. S. 762 (2023): Cited by Justice Jackson for interpretive methodology emphasizing statutory and legislative history as context.
INS v. Stevic, 467 U. S. 407 (1984), Cyan, Inc. v. Beaver County Employees Retirement Fund, 583 U. S. 416 (2018), and Director of Revenue of Mo. v. CoBank ACB, 531 U. S. 316 (2001): Used by Justice Jackson to argue that “conforming amendments” are not the vehicle for radical substantive change.
Price v. Johnson, 600 F. 3d 460 (CA5 2010), and In re Subpoena In Collins, 524 F. 3d 249 (CADC 2008): Justice Jackson uses these to show a pre-2011 split over removability of presuit discovery proceedings—the problem Congress targeted in 2011.

7. Avoiding redundancy

National Assn. of Home Builders v. Defenders of Wildlife, 551 U. S. 644 (2007): Cited for the canon against interpretations that render statutory text redundant, supporting the majority’s rejection of Louisiana’s attempt to merge “acting under” with “relating to.”

B. Legal Reasoning

1. The Court’s operative standard: “close relationship”

The Court articulates a two-step approach. First, it adopts a broad ordinary meaning of “relating to,” informed by preemption cases (Morales v. Trans World Airlines, Inc.; Ingersoll-Rand Co. v. McClendon) and personal-jurisdiction “relate to” usage (Ford Motor Co. v. Montana Eighth Judicial Dist. Court). Second, it imposes a limiting boundary: the relationship must not be “tenuous, remote, or peripheral” (Rutledge v. Pharmaceutical Care Management Assn. (THOMAS, J., concurring)).

2. Application to wartime crude-oil production and avgas refining

The factual “fit” does the work. The parish’s expert theory targeted specific wartime production choices—vertical drilling, canals, earthen pits—asserted to have “illegally commenced” uses. Chevron’s removal theory tied those same choices to wartime federal imperatives: increasing crude-oil output quickly and conserving steel. The Court concluded the connection was close because:

crude oil was an “essential feedstock” for avgas;
Chevron plausibly alleged much of the field’s crude oil went to its own avgas refining;
the challenged practices plausibly increased speed/volume of production and complied with wartime directives;
the Federal Government identified the field as “Critical” and “Essential to the War Program” due to avgas-suitable crude.

On that record, the Court held Chevron satisfied the “relating to” element at the removal stage.

3. Rejecting the Fifth Circuit’s “contract specificity” requirement

The Fifth Circuit effectively demanded that the federal contract specify how Chevron was to obtain crude oil. The Supreme Court treated that as inconsistent with ordinary “relating to” usage: a relationship may exist even if the federal duty did not expressly “invite” the specific conduct. This move materially lowers the barrier for removal in contractor-adjacent contexts where performance depends on upstream inputs (here, crude oil), even if the contract’s text is silent on how those inputs are obtained.

4. Rejecting the “intermediary allocation severs relation” argument

The Fifth Circuit’s second rationale—government allocation breaks the production/refining relation—was rebutted by analogy to Morales v. Trans World Airlines, Inc., where intermediate consumer behavior did not defeat “relating to.” The Court’s rule: intermediaries in the causal chain do not necessarily render the relationship too remote, so long as the overall connection remains close in ordinary terms.

5. Keeping “acting under” distinct from “for or relating to”

Louisiana’s alternative interpretation would have required Chevron to be “acting under” federal direction in the very acts challenged by the complaint (crude-oil production). The Court rejected that reading as textually inconsistent with §1442(a)(1)’s separate clauses and as collapsing the statute’s two distinct elements. By invoking National Assn. of Home Builders v. Defenders of Wildlife, the Court emphasized that “relating to” must have independent function beyond “acting under.”

C. Impact

1. Lower threshold for removal in “input-to-performance” contractor cases

The decision strengthens removal arguments where the challenged state-law conduct involves upstream activities that materially support federal contractual duties (e.g., sourcing, production, logistics, component procurement), even if the contract does not specify those upstream methods. Defendants can frame the nexus as operational necessity and wartime/mission-driven integration rather than textual contractual command.

2. Special significance for legacy environmental and coastal-zone suits

Although the Court cited cases rejecting attenuated links in climate-advertising litigation (District of Columbia v. Exxon Mobil Corp.; Minnesota v. American Petroleum Inst.), its holding will likely be invoked in suits that: (i) target historical extraction/infrastructure practices, and (ii) overlap with historical federal mobilization, procurement, allocation, or directive regimes (especially wartime or emergency authorities). The “close relationship” requirement is the main doctrinal brake; litigants will contest whether a given historical federal program made the challenged activity integral rather than incidental.

3. Federalism and forum effects

By broadening the practical reach of “relating to,” the Court shifts more disputes into federal court when defendants can connect alleged harms to federal operations. This may reduce state-court control over certain categories of environmental tort/regulatory enforcement suits involving federal contractors or federally coordinated industries.

4. Doctrinal uncertainty preserved by the concurrence

Justice Jackson’s concurrence signals an ongoing interpretive dispute: whether “or relating to” displaced the historical causal-nexus test (Willingham v. Morgan; Maryland v. Soper) or merely ensured coverage of presuit discovery proceedings. While the majority’s standard governs, the concurrence provides a ready framework for future litigants and courts seeking to argue for a tighter causation-like requirement.

IV. Complex Concepts Simplified

Federal officer removal (§1442(a)(1)): A procedural mechanism letting federal officers—and certain private parties assisting them—move a state-court case to federal court, aiming to prevent state interference with federal operations.
“Acting under”: A private party may qualify when it is helping a federal officer carry out federal duties (often via government contracts), not merely complying with regulation.
“For or relating to”: The link required between the lawsuit and acts connected to federal office. After this decision, the link can be indirect and need not be strict causation, but must be a close relationship—not “tenuous, remote, or peripheral.”
“Under color of such office”: Acts connected to the defendant’s performance of federal functions; the statute can cover suits that are not directly “for” those acts if they still “relate to” them.
Colorable federal defense: The removing party must assert a plausible federal defense (not decided here), which helps ensure there is a genuine federal issue suitable for Article III courts.
Intermediary in the causal chain: The presence of a third party (here, the P.A.W. allocating crude oil) does not automatically defeat “relating to” if the overall relationship remains close.

V. Conclusion

Chevron USA Inc. v. Plaquemines Parish establishes a clarifying rule for §1442(a)(1): a state-court suit “relates to” federal-officer-directed duties when the defendant plausibly alleges a close operational relationship between the challenged conduct and the performance of federal duties—even if the federal contract does not specifically direct the challenged conduct, and even if intermediaries participate in the chain linking the conduct to federal performance.

The decision reinforces §1442’s protective purpose while preserving a limiting principle against purely attenuated connections. In practice, it will likely expand the availability of a federal forum for defendants facing state-law claims that intersect with historically integrated federal programs, especially where the challenged activity can be characterized as necessary to meet federal production or mission demands.