United States v. Locke
The Supreme Court ruled that several of Washington State's tanker safety rules -- covering crew training, English-language proficiency, navigation watch staffing, and casualty reporting -- are blocked by a federal law that gives the Coast Guard exclusive authority over how tankers are designed, built, staffed, and operated.
The decision revives and reaffirms the Court's 1978 ruling in Ray v. Atlantic Richfield, holding that a 1990 federal oil-spill law did not restore state power to regulate tanker operations, and sends the case back to lower courts to sort out the rest of Washington's rules under the framework the Court laid out.
“Enforcement of the state requirements would at least frustrate what seems to us to be the evident congressional intention to establish a uniform federal regime controlling the design of oil tankers.”
Explaining why federal law leaves no room for state tanker design or operating rules.
How it got here: A federal district court upheld Washington's rules; the Ninth Circuit struck down only one rule; the tanker owners' association and the United States sought Supreme Court review.
The Case in Depth
What happened
After the Exxon Valdez spill dumped millions of gallons of crude oil into Alaska's Prince William Sound, Washington State adopted detailed rules for oil tankers using its waters, including required crew training, English-language skills, minimum watch staffing, and reporting of accidents anywhere in the world. A trade association representing most of the world's independently owned tanker fleet sued state officials, arguing the rules intruded on a field the federal government and international agreements already controlled.
The question before the Court
Could Washington State impose its own crew-training, English-language, watch-staffing, and casualty-reporting rules on oil tankers on top of the federal tanker safety scheme?
Why it matters
Tanker operators moving oil through Puget Sound and other U.S. waters now know that state-by-state crew training, language, staffing, and reporting rules generally cannot be layered on top of national Coast Guard standards. That keeps a single uniform rulebook for the industry, but it also means Washington cannot use several of its own tools meant to reduce the risk of another Exxon Valdez-scale spill in its waters.
What changes now
The Supreme Court struck down four specific Washington rules -- on crew training, English-language proficiency, general navigation watch staffing, and casualty reporting -- as preempted by federal law. It sent the rest of Washington's tanker regulations back to the lower courts to be evaluated individually under the legal framework the Court laid out, distinguishing rules tailored to local water conditions (which may survive) from general operating rules (which likely will not).
What this does not decide
The Court did not decide the fate of Washington's remaining tanker rules, such as its restricted-visibility watch requirement or advance-notice-of-entry rule, leaving those for the lower courts to sort out on remand. It also declined to decide whether international treaties on tanker standards independently preempt state law.
How the Court got there
The legal reasoning, step by step
- The Court revived its 1978 decision in Ray v. Atlantic Richfield, which read the Ports and Waterways Safety Act (PWSA) as having two titles: Title I lets the Coast Guard, and in some cases the states, address purely local port and waterway conditions, while Title II gives only the federal government power over a tanker's design, construction, staffing, and operation nationwide.
- The Court decided that the 1990 Oil Pollution Act's saving clauses -- language sometimes read as preserving broader state authority -- only protected state liability and compensation rules like those in the same title of the 1990 Act, not substantive operating rules like training or staffing requirements found elsewhere in federal law.
- Because Congress had legislated in maritime shipping since the founding era and built an extensive, detailed federal and international regulatory structure, the Court applied no presumption against preemption here, unlike in fields traditionally left to the states.
- Applying Title II's field preemption -- meaning the federal government occupies the whole subject area, leaving no room for state rules even if they don't directly conflict -- the Court found Washington's crew-training and English-language requirements were really rules about 'personnel qualification' and 'operation,' subjects Congress reserved entirely to the Coast Guard.
- The Court applied the same field-preemption logic to Washington's general navigation-watch-staffing rule, since it was not tailored to any local water condition but instead governed how tankers operate generally.
- For the casualty-reporting rule, the Court held that Congress meant the Coast Guard's reporting regulations to be the sole source of a tanker's reporting duties, so a state requirement covering the same ground was preempted even though it did not directly contradict federal rules.
Doctrinal impact
Cases affected by this decision
Reaffirms Ray v. Atlantic Richfield Co. (435 U. S. 151)
The Court reaffirmed Ray's framework distinguishing local-water rules from nationally uniform tanker design and operation rules.
Limits Rice v. Santa Fe Elevator Corp. (331 U. S. 218)
The Court limited Rice's presumption against preemption, saying it does not apply where the federal government has long occupied the field.