Facts
- Washington enacted a “Tanker Law” regulating the design, size, and movement of oil tankers in Puget Sound.
- The law required large tankers (≥50,000 deadweight tons (DWT)) to carry a Washington-licensed pilot while navigating the Sound.
- The law required tankers between 40,000 and 125,000 DWT to meet specified state design/safety standards or, alternatively, operate with tug escorts in the Sound.
- The law prohibited tankers exceeding 125,000 DWT from operating in the Sound.
- Tanker owners and operators challenged the statute, arguing it was preempted by federal law, particularly the Ports and Waterways Safety Act of 1972 (PWSA).
- A three-judge federal district court invalidated the statute in full on federal preemption grounds.
- Federal regulation included PWSA Title I (vessel traffic control, including potential vessel size limits) and Title II (federal regulation of tanker design, construction, and inspection), as well as a federal pilotage statute requiring Coast Guard-licensed pilots for coastwise (enrolled) vessels.
Issues
- Whether federal pilotage law and the PWSA preempt Washington’s requirement that large oil tankers carry a Washington-licensed pilot, especially as applied to enrolled (coastwise) vessels.
- Whether PWSA Title II preempts Washington’s tanker design/safety standards and/or the law’s tug-escort alternative for tankers operating in Puget Sound.
- Whether PWSA Title I preempts Washington’s ban on tankers over 125,000 DWT in Puget Sound.
Decision
- The Supreme Court affirmed in part and reversed in part, rejecting the district court’s conclusion that the Tanker Law was void in its entirety.
- The Court held the state pilotage requirement was preempted as applied to enrolled vessels because federal law vested exclusive pilot-licensing authority for those vessels in the federal government.
- The Court held state-imposed tanker design and construction requirements were preempted by PWSA Title II’s uniform federal regime for tanker design, construction, inspection, and certification.
- The Court indicated the tug-escort requirement could stand as a local operational safety measure if it did not conflict with specific federal regulations governing Puget Sound traffic.
- The Court treated tanker-size restrictions as potentially permissible under PWSA Title I’s traffic-control framework where they complement, rather than conflict with, federal determinations for hazardous local waters.
Legal Principles
- Federal law preempts state law where Congress has occupied a field or where state regulation conflicts with federal purposes or specific federal determinations.
- PWSA Title II establishes a predominantly exclusive federal scheme for tanker design and construction, preempting nonfederal structural standards aimed at vessels.
- State pilotage requirements cannot be imposed on enrolled (coastwise) vessels when federal statutes require Coast Guard-licensed pilots and allocate pilot-licensing authority federally.
- Operational rules directed to local navigation safety (e.g., escorts and traffic precautions) may be valid when federal law has not occupied the field and when there is no direct conflict with federal vessel traffic systems.
- Under PWSA Title I, state measures addressing local hazards may coexist with federal traffic regulation unless they obstruct or contradict federal traffic-control decisions.
Conclusion
The Court required a provision-by-provision preemption analysis: Washington could not impose its own tanker design standards or require state-licensed pilots for enrolled vessels, but certain localized operational and traffic-safety measures—potentially including tug-escort rules and some size limits—could remain effective absent conflict with federal regulation.