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United States v. Washington

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Supreme Court of the United States
United States v. Washington
Term: 2021
Important Dates
Argued: April 18, 2022
Decided: June 21, 2022
Outcome
Reversed and remanded
Vote
9-0
Majority
Stephen Breyer • Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett

United States v. Washington is a case that was decided by the Supreme Court of the United States on June 21, 2022, during the court's October 2021-2022 term. The case was argued before the court on April 18, 2022.

In a unanimous ruling, the court reversed the United States Court of Appeals for the 9th Circuit's decision and remanded the case for further proceedings, holding that Washington’s law discriminates against the federal government and its contractors on its face and is unconstitutional under the Supremacy Clause since §3172 does not clearly waive the federal government's immunity from discriminatory state laws. Justice Stephen Breyer wrote the majority opinion.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned state workers' compensation laws and intergovernmental immunity. Click here to learn more about the case's background.
  • The question presented: "Whether a state workers’ compensation law that applies exclusively to federal contract workers who perform services at a specified federal facility is barred by principles of intergovernmental immunity, or is instead authorized by 40 U.S.C. 3172(a), which permits the application of state workers’ compensation laws to federal facilities “in the same way and to the same extent as if the premises were under the exclusive jurisdiction of the State.”"[2]
  • The outcome: The U.S. Supreme Court reversed the United States Court of Appeals for the 9th Circuit's decision and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit. To review the lower court's opinion, click here.[3]

    Timeline

    The following timeline details key events in this case:

    Background

    The Hanford site ("Hanford") is a decommissioned federal nuclear production site located in southeastern Washington State. While active from 1944 to 1989, the site produced weapons-grade plutonium and generated radioactive and chemically hazardous waste.[3] Since 1989, the United States Department of Energy (DOE) has overseen Hanford's cleanup through private contractors and subcontractors, who perform the cleanup work.[3]

    Under Washington state law, private contractors' employees working on federal land may pursue state workers' compensation claims. The DOE insured the claims for most of its contractors at the Hanford site. In 2018, Washington amended its workers' compensation law by enacting HB 1723, a law that applies specifically to the Hanford workers employed by the United States, directly or indirectly. The law establishes that certain medical conditions and cancers are occupational diseases. One may rebut this presumption with clear and convincing evidence.[3]

    Following the passage of the law, the United States sued Washington, arguing that there was now increased liability and claiming that HB 1723 violated the doctrine of intergovernmental immunity by directly regulating and discriminating against the federal government. The United States District Court for the Eastern District of Washington granted summary judgment in favor of Washington, according to a congressional immunity waiver that allows states to apply workers' compensation laws to federal land and projects as would be done if the land and projects were exclusively under the state's jurisdiction.[3]

    On appeal, the 9th Circuit held that HB 1723 did not violate the intergovernmental immunity doctrine and affirmed the Eastern District of Washington's judgment.[3]

    On September 8, 2021, the U.S. government appealed to the Supreme Court of the United States. On January 10, 2022, SCOTUS agreed to hear the case argued on the merits during its October 2021-2022 term.

    Question presented

    The petitioner presented the following question to the court:[2]

    Question presented:
    “ Whether a state workers’ compensation law that applies exclusively to federal contract workers who perform services at a specified federal facility is barred by principles of intergovernmental immunity, or is instead authorized by 40 U.S.C. 3172(a), which permits the application of state workers’ compensation laws to federal facilities “in the same way and to the same extent as if the premises were under the exclusive jurisdiction of the State.”[4] ”

    Oral argument

    Audio

    Audio of oral argument:[5]



    Transcript

    Transcript of oral argument:[6]

    Outcome

    In a unanimous ruling, the court reversed the United States Court of Appeals for the 9th Circuit's decision and remanded the case for further proceedings, holding that Washington’s law discriminates against the federal government and its contractors on its face and is unconstitutional under the Supremacy Clause since §3172 does not clearly waive the federal government's immunity from discriminatory state laws. Justice Stephen Breyer wrote the majority opinion.[1]

    Opinion

    In the court's majority opinion, Justice Stephen Breyer wrote:[1]

    “ The Constitution’s Supremacy Clause generally immunizes the Federal Government from state laws that directly regulate or discriminate against it. See South Carolina v. Baker, 485 U. S. 505, 523 (1988). Congress, however, can authorize such laws by waiving this constitutional immunity. See Goodyear Atomic Corp. v. Miller, 486 U. S. 174, 180 (1988)


    ... The question before us is whether a Washington State workers’ compensation law falls within the scope of this congressional waiver. The state law, by its terms, applies only to federal workers who work at one federal facility in Washington. The law makes it easier for these workers to obtain workers’ compensation, thus raising workers’ compensation costs for the Federal Government. We conclude that the state law discriminates against the Federal Government and falls outside the scope of Congress’ waiver. We therefore hold that the law is unconstitutional under the Supremacy Clause.[4]

    		”
    —Justice Stephen Breyer

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[7]

    The court agreed to hear 68 cases during its 2021-2022 term.[8] Four cases were dismissed and one case was removed from the argument calendar.[9]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 U.S. Supreme Court, United States v. Washington, decided June 21, 2022
    2. ↑ 2.0 2.1 U.S. Supreme Court, "United States v. Washington: PETITION FOR A WRIT OF CERTIORARI," filed September 8, 2021
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 U.S. Court of Appeals for the 9th Circuit, United States v. Washington, decided August 19, 2020
    4. ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 18, 2022
    6. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 18, 2022
    7. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    8. ↑ Consolidated cases are counted as one case for purposes of this number.
    9. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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