United States v. Washington
In brief
The Supreme Court unanimously overturned the Ninth Circuit’s ruling and sent the case back, deciding that Washington’s law is unconstitutional under the Supremacy Clause.
- Where it stands
- Decided
Decided · June 21, 2022 · Opinion by Justice Breyer
- What it’s about
- The Supreme Court unanimously overturned the Ninth Circuit’s ruling (reversed it) and sent the case back to that court (remanded it).
- Who it affects
- The Court found Washington’s law unconstitutional under the Supremacy Clause because §3172(a) does not clearly and unambiguously waive the Federal Government’s immunity from discriminatory state laws.
Summary: written with AI from the case record.
What it's about
It decided that Washington’s workers’ compensation law treats the Federal Government and its contractors differently on its face, and that 40 U.S.C. §3172(a) does not clearly waive immunity from such state discrimination, making the law unconstitutional under the Supremacy Clause.
The case shows how intergovernmental immunity can limit state rules that treat the Federal Government and its contractors differently at federal facilities.
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."?
What the Court decided
Holding
Washington’s law facially discriminates against the Federal Government and its contractors. Because §3172 does not clearly and unambiguously waive the Federal Government’s immunity from discriminatory state laws, Washington’s law is unconstitutional under the Supremacy Clause. 994 F. 3d 994, reversed and remanded.
- Result
- Reversed
The vote
- Majority author
- Stephen G. Breyer
What's next
The case returns to the Ninth Circuit for further proceedings. That court must apply the Supreme Court’s ruling when it handles the dispute again.
Why it matters
The case returns to the Ninth Circuit for further proceedings.
Documents
Docket activity
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AI analysis generated: Case Briefing
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Brief added: Questions Presented
More questions
- What did United States v. Washington decide?
- The Court decided Washington’s law treats the Federal Government and its contractors differently in the law’s wording. It found the law unconstitutional under the Supremacy Clause.
- How did the Supreme Court rule in this case?
- It unanimously overturned the Ninth Circuit’s ruling and sent the case back to that court (reversed and remanded).
- Why did the Court reject Washington’s law?
- Section 3172(a) does not clearly and unambiguously waive federal immunity from discriminatory state laws. That made Washington’s law unconstitutional under the Supremacy Clause.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.