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United States v. Massachusetts

ELR Citation: 37 ELR 20149
Nos. Nos. 06-2361, -2362, (1st Cir., 06/21/2007)

The court vacated a lower court decision in favor of the U.S. government in their suit seeking to enjoin enforcement of a Massachusetts law designed to reduce the risk of maritime oil spills and to ensure that adequate resources are available to remedy such spills. The U.S. government filed suit against Massachusetts on the ground that the Massachusetts Oil Spill Prevention Act was preempted by the Ports and Waterways Safety Act, as amended by the Port and Tanker Safety Act of 1978 (collectively, PWSA). The commonwealth argued that Congress had given the states leeway to regulate particularly sensitive local waterways, at least in the absence of an actual conflict with a federal statute or regulation, and that there was no conflict here. The lower court concluded, as a matter of judgment on the pleadings, that the PWSA left no room for the state government to enact these state statutory provisions and permanently enjoined the challenged provisions. In so doing, the court did not adhere to the analytical structure the U.S. Supreme Court has required to resolve federal-state conflicts in this area. Rather, it acted prematurely. Thus, the lower court erred in entering permanent injunctions, as well as in entering judgment for the United States, at this early stage of the proceedings.