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United States v. Locke

Supreme Court of the United States · 2000 · Constitutional Law

Constitutional LawFederal PreemptionMaritime RegulationSupremacy Clausepreemptionmaritime commercePorts and Waterways Safety ActOil Pollution Act of 1990

Facts

After the Exxon Valdez spill, Washington adopted extensive tanker regulations governing design, equipment, reporting, crew training, language proficiency, and operating practices for vessels entering its waters. Intertanko challenged these rules as inconsistent with the comprehensive federal scheme regulating oil tankers. The Court considered the continuing force of the Ports and Waterways Safety Act and whether the Oil Pollution Act of 1990 altered the preemption analysis established in Ray v. Atlantic Richfield. The specific rules addressed in detail included crew training, English language proficiency, navigation watch requirements, and casualty reporting.

Issue

Whether Washington may enforce its post-Exxon Valdez tanker regulations in light of the federal statutory and regulatory scheme governing maritime oil tankers. More specifically, whether the Oil Pollution Act of 1990 displaced Ray v. Atlantic Richfield's preemption framework and whether particular Washington rules are preempted under Title I or Title II of the Ports and Waterways Safety Act or other federal law.

Rule

The Oil Pollution Act of 1990 did not alter the preemptive effect of the Ports and Waterways Safety Act. Under Title I of the PWSA, a State may regulate local ports and waterways based on peculiar local conditions only if the regulation does not conflict with Coast Guard regulation or a Coast Guard determination that regulation is unnecessary; this is conflict preemption. Under Title II, the Federal Government exclusively regulates tanker design, construction, alteration, repair, maintenance, operation, equipping, personnel qualification, and manning, so state regulation of those subjects is field preempted.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

California adopts a rule requiring every oil tanker entering Long Beach Harbor to certify that all bridge officers completed a state-approved fatigue-management and spill-response training course within the last year. The course may be taken anywhere in the world before the vessel begins its voyage to California.

Is the California rule most likely preempted?

Explanation. The rule is most likely preempted. The majority held that state crew-training requirements fall within Title II of the Ports and Waterways Safety Act, which reserves to the Federal Government regulation of vessel operation, personnel qualification, and manning. A state cannot avoid preemption by saying the training is safety-related or spill-prevention oriented. The training requirement also has extraterritorial effect because it dictates staffing and preparation before the vessel reaches local waters.