UNITED STATES v. LOCKE, GOVERNOR OF WASHINGTON, et al.
529 U.S. 89 (2000)
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Rule of Law:
Under the Ports and Waterways Safety Act (PWSA), federal law establishes a comprehensive regulatory scheme for oil tankers that occupies the field of vessel design, construction, operation, manning, and personnel qualifications (Title II), thereby preempting state regulations in these areas. States may only regulate local maritime conditions based on unique local needs (Title I) if such regulations do not conflict with federal law or policy.
Facts:
- The State of Washington contains environmentally sensitive and commercially significant waters, including Puget Sound, which is a major destination and transit route for oil tankers.
- Following the 1989 Exxon Valdez oil spill, Washington's legislature directed the state's Office of Marine Safety to establish spill prevention standards providing the 'best achievable protection' (BAP) from oil discharges.
- Pursuant to this directive, Washington promulgated a comprehensive set of regulations imposing specific requirements on tankers operating in its waters.
- These regulations covered crew training, English language proficiency, navigation watch procedures, casualty reporting from anywhere in the world, and vessel equipment, among other areas.
- The International Association of Independent Tanker Owners (Intertanko), a trade association representing approximately 80% of the world's independent tanker fleet, found these state-specific rules to be inconsistent with uniform national and international standards.
- Thirteen foreign nations formally expressed concern that Washington's rules would create inconsistency and undermine the international maritime regulatory regime, which is based on the principle of reciprocity and uniform standards.
Procedural Posture:
- The International Association of Independent Tanker Owners (Intertanko) filed a lawsuit in the U.S. District Court for the Western District of Washington against state officials, seeking declaratory and injunctive relief from Washington's 'best achievable protection' (BAP) regulations.
- The District Court granted summary judgment in favor of Washington, upholding all the challenged regulations.
- Intertanko, the appellant, appealed to the U.S. Court of Appeals for the Ninth Circuit. The United States intervened on Intertanko's behalf.
- The Court of Appeals affirmed the District Court's decision for most of the regulations, finding that the Oil Pollution Act of 1990 (OPA) limited the preemptive effect of federal law that was established in a prior Supreme Court case. The court struck down only one regulation concerning equipment.
- The United States Supreme Court granted certiorari.
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Issue:
Are Washington state's regulations governing oil tanker design, equipment, reporting, and operations preempted by the comprehensive federal regulatory scheme, particularly the Ports and Waterways Safety Act (PWSA)?
Opinions:
Majority - Justice Kennedy
Yes. Federal law preempts Washington's regulations governing general tanker operations, personnel qualifications, and casualty reporting because Congress intended to create a uniform national and international regulatory scheme for maritime commerce. The Court's analysis in Ray v. Atlantic Richfield Co. remains controlling. The Ports and Waterways Safety Act (PWSA) creates a dual framework for preemption: Title II preempts the entire field of tanker design, construction, operation, and manning to ensure uniformity, while Title I permits state regulation of local port conditions only if it does not conflict with federal law. The Oil Pollution Act of 1990 (OPA) did not alter this framework; its saving clauses preserve state authority only over liability and compensation, not over the substantive regulation of vessel operations. The Court held that Washington's rules on crew training, English language proficiency, and general navigation watch procedures are preempted by Title II's field preemption because they regulate 'personnel qualifications,' 'operation,' and 'manning.' The state's casualty reporting rule is also preempted because Congress intended federal Coast Guard regulations to be the sole source of reporting obligations to create a uniform system.
Analysis:
This decision significantly reinforces the doctrine of federal preemption in maritime commerce, establishing a strong presumption in favor of uniform federal regulation over state-specific environmental laws. By narrowly interpreting the saving clauses of the Oil Pollution Act of 1990, the Court prevented states from creating a patchwork of conflicting operational standards for vessels in interstate and international trade. The case clarifies the distinction between permissible state regulation of unique local conditions (conflict preemption under PWSA Title I) and impermissible state intrusion into federally occupied fields of general vessel regulation (field preemption under PWSA Title II). This holding serves as a major check on state efforts to enact environmental regulations that exceed federal standards in the maritime context, thereby prioritizing national uniformity and international comity in shipping.
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