## Facts

- Florida enacted the Florida Oil Spill Prevention and Pollution Control Act (1970) to address sea-to-shore oil pollution.
- The Act authorized the State to recover oil-spill cleanup costs and damages and imposed strict, no-fault liability on waterfront oil-handling facilities and ships calling at such facilities.
- The Act also provided liability to private persons injured by oil spills.
- Merchant shipowners and operators, shipping associations, and related industry entities sued in federal court to enjoin enforcement, claiming federal preemption by the Water Quality Improvement Act of 1970 (WQIA) and by federal admiralty law.
- A three-judge federal district court held the Florida statute unconstitutional on preemption grounds and enjoined its application.

## Issues

1. Whether the WQIA preempts a state statute imposing strict, no-fault liability and damages remedies for oil spills affecting a state’s coastal waters and shore.
2. Whether federal admiralty jurisdiction and the Admiralty Extension Act preempt state police-power regulation and remedies for sea-to-shore oil pollution.

## Decision

- The Supreme Court unanimously reversed (Douglas, J.).
- The Court held the Florida Act was not preempted by the WQIA because the federal statute focused on recovery of federal cleanup costs and contemplated coordinated federal-state action against coastal oil pollution.
- The Court held the Admiralty Extension Act did not supply an exclusive federal remedy barring state regulation and damages remedies for sea-to-shore pollution.
- Florida was permitted to enforce its statute.

## Legal Principles

- Absent clear congressional intent to displace state authority, states may exercise police power to protect coastal waters and shorelines through environmental statutes, including strict-liability oil-spill regimes.
- The WQIA does not occupy the field of oil-spill liability; its federal cleanup-cost recovery framework can coexist with stricter state remedies for state and private damages.
- Federal admiralty jurisdiction and the Admiralty Extension Act do not automatically preempt state environmental regulation where state law addresses onshore/coastal harms and does not purport to rewrite core maritime rules.
- Preemption requires either clear field occupation or an actual conflict; complementary state measures consistent with federal cooperative objectives may stand.

## Conclusion

The Court upheld Florida’s oil-spill strict-liability statute, concluding that federal oil-pollution legislation and admiralty law did not provide exclusive remedies or otherwise preempt state authority to impose broader liability and damages for sea-to-shore pollution.


Askew v. Am. Waterways Operators, Inc., 411 U.S. 325 (1973)