United States v. Washington
The Facts
Washington created a special workers' compensation scheme for employees at the Hanford nuclear site, providing additional remedies for workers who could show their occupational disease was more likely than not related to toxic exposure at the facility. Federal contractor employees and the United States challenged the law as preempted by federal law.
The Application
Applying the preemption doctrine to Washington's scheme, the Court found that the state's occupational disease compensation law for Hanford workers directly conflicted with the federal nuclear regulatory framework and the Price-Anderson Act's comprehensive compensation structure. Although Washington sought to provide additional remedies for workers with occupational disease tied to toxic exposure, the state-law cause of action permitting recovery based on a more-likely-than-not causal nexus created obligations that displaced federal authority and imposed inconsistent requirements on federal contractors at this federally operated facility. The state's attempt to supplement federal nuclear worker protections with state-law remedies conflicted with Congress's carefully balanced scheme and could not coexist alongside the federal regulatory regime governing nuclear safety and compensation.
The Conclusion
**United States v. Washington invalidated Washington State's occupational disease compensation scheme for nuclear workers as preempted by federal law, reinforcing federal supremacy in the nuclear regulatory domain.** The ruling has significant implications for state efforts to provide additional protections to workers at federally operated or contracted nuclear sites and the scope of state authority over nuclear worker health and safety.
No circuit court data for this case.
Case Analysis
Overview
Washington State enacted a workers' compensation law for employees of federal contractors working at a nuclear facility, creating cause of action for occupational disease. The Supreme Court held 5-4 that the state law was preempted by federal law governing nuclear facilities, because state tort-like remedies for nuclear workers' compensation conflicts with the federal regulatory scheme for nuclear safety and worker compensation.
Facts
Washington created a special workers' compensation scheme for employees at the Hanford nuclear site, providing additional remedies for workers who could show their occupational disease was more likely than not related to toxic exposure at the facility. Federal contractor employees and the United States challenged the law as preempted by federal law.
Issue
Whether Washington's nuclear workers' compensation law is preempted by federal law, including the Price-Anderson Act and the federal scheme for regulating nuclear facilities and compensation.
Rule
State laws that conflict with federal regulatory schemes governing nuclear facilities are preempted under the Supremacy Clause. Where Congress has established a comprehensive federal framework for nuclear worker safety and compensation, state laws that create additional or conflicting obligations for federal contractors are displaced.
Analysis
Applying the preemption doctrine to Washington's scheme, the Court found that the state's occupational disease compensation law for Hanford workers directly conflicted with the federal nuclear regulatory framework and the Price-Anderson Act's comprehensive compensation structure. Although Washington sought to provide additional remedies for workers with occupational disease tied to toxic exposure, the state-law cause of action, permitting recovery based on a more-likely-than-not causal nexus, created obligations that displaced federal authority and imposed inconsistent requirements on federal contractors at this federally operated facility. The state's attempt to supplement federal nuclear worker protections with state-law remedies conflicted with Congress's carefully balanced scheme and could not coexist alongside the federal regulatory regime governing nuclear safety and compensation.
Conclusion
**United States v. Washington invalidated Washington State's occupational disease compensation scheme for nuclear workers as preempted by federal law, reinforcing federal supremacy in the nuclear regulatory domain.** The ruling has significant implications for state efforts to provide additional protections to workers at federally operated or contracted nuclear sites and the scope of state authority over nuclear worker health and safety.
Notes
OT2021. Added via SCOTUS bulk import 2026-05-14
Flag an issue
This tracker is maintained by BrynoDC and is free because readers fund it. Support