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Ray v. Atlantic Richfield Co., 435 U.S. 151, 98 S.Ct. 988, 55 L.Ed.2d 179, 11 ERC 1273, 1978 A.M.C. 527, 8 Envtl. L. Rep. 20,255

Facts

The Washington Tanker Law was enacted to regulate the design, size, and movement of oil tankers in Puget Sound. It included provisions requiring certain tankers to carry state-licensed pilots, meet specific design standards, and imposed size limitations on tankers. The law was challenged by Atlantic Richfield Co. and Seatrain Lines, who argued that it was unconstitutional and preempted by federal law, particularly the Ports and Waterways Safety Act.

Located adjacent to Puget Sound are six oil refineries having a total combined processing capacity of 359,500 barrels of oil per day.

Issue

The main legal issues were whether the Washington Tanker Law was preempted by federal law and whether its provisions conflicted with federal regulations regarding oil tankers.

The District Court held that under the Supremacy Clause, Art. VI, cl. 2, of the Constitution, which declares that the federal law 'shall be the supreme Law of the Land,' the Tanker Law could not coexist with the PWSA and was totally invalid.

Rule

The court applied the Supremacy Clause, which establishes that federal law takes precedence over state law when there is a conflict. It also considered the intent of Congress in enacting the Ports and Waterways Safety Act, which aimed to create uniform national standards for tanker design and operation.

To the extent that § 88.16.180 requires enrolled tankers to carry state-licensed pilots, the State is precluded by 46 U.S.C. §§ 215, 364 from imposing its own pilotage requirements and to that extent the state law is invalid.

Analysis

The court found that certain provisions of the Tanker Law directly conflicted with federal statutes, particularly those requiring state-licensed pilots for enrolled tankers and imposing design standards. However, it ruled that the state could still require tug escorts for tankers that did not meet federal design standards, as the Secretary of Transportation had not established his own requirements in that area.

The PWSA contains two Titles representing somewhat overlapping provisions designed to insure vessel safety and the protection of the navigable waters, their resources, and shore areas from tanker cargo spillage.

Conclusion

The Supreme Court affirmed in part and reversed in part the District Court's ruling, allowing some provisions of the Tanker Law to stand while invalidating others that were preempted by federal law.

The exclusion from Puget Sound of any tanker exceeding 125,000 DWT pursuant to § 88.16.190(1) is invalid under the Supremacy Clause in light of Title I and the Secretary's actions thereunder.

Who won?

The prevailing party was the federal government, as the Supreme Court upheld the preemption of several provisions of the Tanker Law by federal legislation.

The three-judge court agreed with the plaintiffs and the United States, ruling that all of the operative provisions of the Tanker Law were pre-empted, and enjoining appellants and their successors from enforcing the chapter.

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