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Keywords

statuteregulation

Related Cases

State v. Turnbaugh, Not Reported in A.2d, 1995 WL 941421

Facts

Brian E. Turnbaugh, a Rhode Island resident, owns the vessel 'All Maine Woman,' which is federally documented and licensed for commercial fishing. The state charged him with violating registration requirements under Rhode Island law, which he contended were preempted by federal law. The state argued that it could require additional registration for documented vessels, despite federal regulations governing their documentation and licensing.

Brian E. Turnbaugh, a resident of Rhode Island, is presently and has been since March 23, 1984, the owner of the vessel, ‘All Maine Woman,‘ an oil screw home ported in Boston, Massachusetts. This vessel is documented and endorsed for ‘Fishery‘ and possesses a Certificate of Documentation as required by Federal law.

Issue

Is the Rhode Island statute requiring registration and fees for federally documented vessels preempted by federal law, and does it violate the Supremacy Clause of the U.S. Constitution?

Rule

Federal preemption occurs when Congress has legislated comprehensively in a field, leaving no room for state regulation, or when state laws conflict with federal laws.

Analysis

The court found that the federal government has established a comprehensive scheme for the documentation and licensing of commercial vessels, indicating a clear intent to preempt state regulation in this area. The Rhode Island statute was deemed to conflict with federal law, as it imposed additional registration requirements and fees on vessels already documented under federal law, which the state cannot do.

Conclusion

The court declared the Rhode Island statute unconstitutional, ruling that it imposed an impermissible burden on interstate commerce and violated the Supremacy Clause.

Who won?

Brian E. Turnbaugh prevailed in the case because the court found that the state law conflicted with federal regulations governing documented vessels, thus rendering it unconstitutional.

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Keywords

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