## Facts

- California’s Labor Commissioner enforced California overtime requirements against maritime employers operating vessels off the California coast in California territorial waters.
- The vessels at issue did not conduct foreign, intercoastal, or coastwise voyages; the work was tied to in-state waters and operations.
- Maritime employer associations and a member company sought declaratory and injunctive relief, asserting California overtime law was displaced by federal maritime law and federal seamen’s wage statutes.
- A maritime employer intervened after an employee filed an overtime wage claim with the state labor enforcement agency.
- The district court granted summary judgment to the employers, declared the state overtime regime preempted as applied, and enjoined further enforcement.

## Issues

1. Whether California overtime laws, as applied to seamen working primarily in California territorial waters, are displaced by general maritime law or preempted by federal seamen’s wage statutes.
2. Whether applying state overtime rules in this setting improperly impairs maritime-law uniformity in interstate and international relations.

## Decision

- The Ninth Circuit reversed the summary judgment and vacated the injunction barring enforcement.
- The court held California’s overtime laws were not preempted or displaced when applied to the maritime employment at issue.
- The case was remanded for further proceedings consistent with allowing state enforcement.

## Legal Principles

- State law may apply in maritime contexts unless it materially prejudices characteristic features of general maritime law or interferes with maritime uniformity in interstate and international relations.
- Federal maritime jurisdiction and federal regulation of seamen’s wages do not, by themselves, occupy the entire field of wage-and-hour regulation or bar supplementary state protections.
- Absent a clear congressional directive, courts generally permit state worker-protection measures for employment performed within a state’s territorial waters.
- Uniformity concerns bar only state rules that seriously conflict with an exclusive federal maritime regime; limited variations in local wage obligations may be permissible where impacts on interstate and international maritime relations are slight.

## Conclusion

The court held that California could enforce its overtime laws against maritime employers for seamen working in California territorial waters because neither general maritime law nor federal wage statutes displaced the state regime, and the application did not create the type of conflict or nonuniformity that federal admiralty law forbids.


Pac. Merch. Shipping Ass'n v. Aubry, 918 F.2d 1409 (9th Cir. 1990)