United States v. Washington
Headline: State law that singled out federal Hanford cleanup workers is struck down, blocking Washington’s special workers’ compensation rule that raised costs for the Federal Government and limited state favoritism toward contractors.
Holding: Washington’s Hanford workers’ compensation law unlawfully discriminates against the Federal Government because Congress did not clearly waive federal immunity for that kind of discriminatory state law.
- Blocks state laws that single out federal contractors for special compensation benefits.
- Allows the Federal Government to avoid or recover millions in Hanford compensation costs.
- Limits states’ ability to shift unique costs onto the federal government by favoring residents.
Summary
Background
In 2018 Washington passed a workers’ compensation law that applied only to people working under federal contracts at the Hanford nuclear cleanup site. That law created a lifetime presumption that certain illnesses were caused by Hanford work, making it easier for those contract workers to win benefits. The United States sued, saying the law discriminated against the Federal Government because it raised costs federal contractors’ employer (the Government) would have to pay. Lower courts found the law permissible based on a federal statute, 40 U. S. C. §3172, and the Government appealed to the Supreme Court.
Reasoning
The Court asked whether Congress clearly waived the Federal Government’s immunity so a State could enact a law that singled out federal workers. The Justices explained that the Constitution bars States from treating the Federal Government or its contractors unfavorably. Because §3172 can be read narrowly to let States extend their generally applicable workers’ compensation laws to federal lands—but does not clearly and unambiguously authorize laws that explicitly discriminate—the Court concluded Congress had not waived immunity here. The Court therefore held Washington’s targeted Hanford rule unconstitutional and reversed the Ninth Circuit. The opinion was unanimous and delivered by Justice Breyer.
Real world impact
The ruling prevents Washington’s special Hanford-only compensation rule from standing and could let the Federal Government avoid or seek repayment of millions in claims. The Court also rejected Washington’s mootness claim, noting the Government said a win could recover $17–$37 million. The decision limits States’ ability to favor their residents by shifting unique costs onto the Federal Government and will shape how similar state laws affecting federal projects are evaluated.
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