United States v. Locke

Facts of the Case

Appellee owners of forfeited mining claims on federal lands, failed to timely file the annual notice of their intent to hold their claims and thereby forfeited their claims under the Federal Land Policy and Management Act of 1976 (FLPMA), 43 U.S.C.S. §§ 1701 et seq. After losing an administrative appeal before the Bureau of Land Management, appellees brought an action in district court challenging the forfeitures. The district court held that the forfeiture provisions of the FLPMA violated the Fifth Amendment. The government consequently appealed.

Question

Are the State of Washington’s maritime regulations on tanker design, equipment, reporting, and operating requirements pre-empted by federal law?

CONCLUSION

Yes. In a unanimous opinion delivered by Justice Anthony Kennedy, the Court held that Washington’s regulations regarding general navigation watch procedures, crew English-language skills and training, and maritime casualty reporting are pre-empted by the comprehensive federal regulatory scheme governing oil tankers. The State of Washington has enacted legislation in an area where the federal interest has been manifest since the beginning of our Republic and is now well established, wrote Justice Kennedy for the Court. Justice Kennedy also noted that States may regulate their own ports and waterways so long as the rules are based on the peculiarities of local waters and do not conflict with federal regulation.

Case Information

  • Citation: 529 US 89 (2000)
  • Argued: Dec 7, 1999
  • Decided Mar 6, 2000