Chevron U.S.A., Inc. v. William J. Sheffield, Governor of Alaska

Background

The dispute involves the State of Alaska and oil companies over a state law that forbids any discharge of seawater used as ballast from tankers in Alaskan waters. The United States Court of Appeals for the Ninth Circuit held that Alaska’s Tanker Act was not preempted by Coast Guard regulations issued under Title II of the Ports and Waterways Safety Act (PWSA). Federal regulations allow some discharge within 50 miles if the water meets cleanliness standards, while Alaska’s law bars any such discharge in its territorial waters.

Reasoning

The central question was whether federal Coast Guard regulations under Title II of the PWSA override Alaska’s stricter rule. The Ninth Circuit concluded the state rule was not displaced by federal rules, in part because the court viewed operational rules as less in need of national uniformity than design and construction standards. Justice White, in dissent from the denial of review, argued that an earlier decision (Ray v. Atlantic Richfield Co.) supports federal preemption where state and federal rules aim at the same environmental protection goals.

Real world impact

The Supreme Court declined to review the appeals court’s ruling, so the lower-court decision remains in effect for now and the Alaska ban stands as applied. The opinion respecting denial noted the limited practical effect: apparently only one older vessel may be affected, some ports have onshore reception facilities that allow compliance, and no other State has adopted a similar ban. The Coast Guard retains authority to change its regulations, so the regulatory situation could still shift.

Dissents or concurrances

Justice White would have granted review, emphasizing similarity to Ray and arguing federal rules should displace the state law because both aim to protect the marine environment.