United States v. Locke
Headline: Washington’s tanker safety rules are partly blocked — the Court says federal maritime law preempts several state requirements, making certain state rules unenforceable while others need further review.
Holding:
- Blocks Washington enforcement of some crew training requirements on tankers.
- Invalidates state English-proficiency and general navigation watch rules for tankers.
- Preempts Washington-required incident reporting that duplicates federal reporting.
Summary
Background
A trade association for tanker owners and operators challenged Washington State’s “best achievable protection” (BAP) tanker rules. Washington created an Office of Marine Safety and adopted detailed rules for tanker design, crew training, language, watch practices, and reporting (WAC §§317-21-130 et seq.). The dispute followed major spills (Torrey Canyon and Exxon Valdez) and lower courts reached conflicting results before the appeal to this Court.
Reasoning
The central question was whether Washington’s newer rules can stand alongside a comprehensive federal maritime scheme. The Court explained that some matters — including tanker design, operation, personnel qualifications, and manning — are reserved for national regulation under Title II of the Ports and Waterways Safety Act and related federal statutes and Coast Guard rules. The Court also held that the Oil Pollution Act’s liability “saving clauses” preserve state liability regimes but do not undo the PWSA’s federal regulatory pre-emption. As a result, the Court found certain Washington requirements preempted (training, English proficiency, general navigation watch, and incident reporting) and sent other parts of the state program back to lower courts for review under the federal-state framework the opinion describes.
Real world impact
The decision limits Washington’s ability to enforce some detailed operational rules against tankers and emphasizes national uniformity for crew qualifications and vessel operations. The Court reversed the Ninth Circuit on pre-emption questions, remanded remaining claims for further factual and legal analysis, and noted the Coast Guard and Congress retain primary responsibility for uniform tanker rules. This ruling is not a final resolution of every state regulation; further proceedings will determine the fate of the remaining requirements.
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