New York v. New Jersey | |
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Argued March 1, 2023 Decided April 18, 2023 | |
Full case name | New York v. New Jersey |
Docket no. | 22O156 |
Citations | 598 U.S. 218 ( more ) |
Argument | Oral argument |
Opinion announcement | Opinion announcement |
Holding | |
New Jersey has the unilateral right to withdraw from the Waterfront Commission of New York Harbor. | |
Court membership | |
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Case opinion | |
Majority | Kavanaugh, joined by unanimous |
New York v New Jersey, 598 U. S. 218 (2023), is a United States Supreme Court case in which the Court held that New Jersey had the right to unilaterally withdraw from the Waterfront Commission of New York Harbor.
In 1953, New York and New Jersey entered a compact establishing the Waterfront Commission of New York Harbor, a bistate commission for regulating and enforcing the law in the Port of New York and New Jersey shared by the states. For approximately 60 years, the states collaborated through the commission to combat lawlessness and disinfect the port of charlatans and malign opportunists. However, by the 2010s, New Jersey lost interest in continued participation in the commission, as it became irrelevant and costly in their view. In 2018, the New Jersey Legislature passed, and Governor of New Jersey Chris Christie subsequently signed, legislation authorizing the state's withdrawal from the commission. [1] New York moved to enjoin the withdrawal, arguing that New Jersey could not unilaterally withdraw from the compact. The Supreme Court temporarily enjoined the withdrawal, and exercised its original jurisdiction to adjudicate the case. [2] [3]
In a unanimous decision, Justice Kavanaugh delivered the opinion of the Court, holding that New Jersey had the right to unilaterally withdraw from the compact. [4] [5] Two important principles underlay the Court's decision: (1) Interstate compacts are viewed as contracts, and are interpreted using the procedures thereof. (2) Waiver of sovereign immunity should not be treated lightly, and any expansion of such waiver must be undertaken diligently and meticulously.
The first principle establishes the framework for interpreting the compact. Absent express instructions, contracts may be terminated by any party at any time the party sees fit. Thus, given the compact's silence regarding unilateral withdrawal, a state may unilaterally withdraw from an interstate compact. State sovereignty principles, which look askance at any diminishment of state self-governance, support this conclusion. [6] However, the Court maintained that some compacts are not subject to the same analysis, for example, compacts conveying property interests, compacts not indefinite in their validity, or compacts with express instructions as to withdrawal. As the Court explained, the circumstances of such compacts suggest or directly express the intent of the party, and thus, in those cases, the parties’ intent should control. [7]
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The Waterfront Commission of New York Harbor (WCNYH) was a regulatory agency in the Port of New York and New Jersey in the northeast of the United States. The bi-state agency was founded in 1953 by a Congressional authorized compact between New York and New Jersey "for the purpose of eliminating various evils on the waterfront in the Port of New York Harbor." Under statutory mandate, the mission of the commission is to investigate, deter, combat and remedy criminal activity and influence in the port district and also ensures fair hiring and employment practices.
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There have been various proposals for the United States to withdraw from the United Nations, where it is one of the founding members and one of the five permanent members of the United Nations Security Council.
The Treaty Clause of the United States Constitution establishes the procedure for ratifying international agreements. It empowers the President as the primary negotiator of agreements between the United States and other countries, and holds that the advice and consent of a two-thirds supermajority of the Senate renders a treaty binding with the force of federal law.
De Veau v. Braisted, 363 U.S. 144 (1960), is a 5-to-3 ruling by the Supreme Court of the United States that an interstate compact restricting convicted felons from holding union office is not preempted by the National Labor Relations Act or the Labor Management Reporting and Disclosure Act, does not violate the Due Process Clause of the 14th Amendment, and is not an ex post facto law or bill of attainder in violation of Article One, Section 10 of the Constitution.
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United Gas Pipe Line Co. v. Ideal Cement Co., 369 U.S. 134 (1962), is a United States Supreme Court case which vacated a lower appellate court decision, holding that federal courts should abstain from ruling on the constitutionality of a state tax issue that state courts should determine.
Lorain Journal Co. v. United States, 342 U.S. 143 (1951), is a decision of the United States Supreme Court that is often cited as an example of a monopolization violation being based on unilateral denial of access to an essential facility although it in fact involved concerted action. When the Lorain Journal monopoly over advertising in the Lorain, Ohio, area was threatened by the establishment of a competing radio station, the newspaper's publisher refused to accept advertising from those who advertised over the radio station and required them to advertise only in the Journal. The purpose of the publisher was to eliminate the competition of the radio station. The Supreme Court held that the publisher had attempted to monopolize trade and commerce in violation of § 2 of the Sherman Antitrust Act and was properly enjoined from continuing its conduct.
Murphy v. National Collegiate Athletic Association, No. 16-476, 584 U.S. 453 (2018) [138 S. Ct. 1461], was a United States Supreme Court case involving the Tenth Amendment to the United States Constitution. The issue was whether the U.S. federal government has the right to control state lawmaking. The State of New Jersey, represented here by Governor Philip D. Murphy, sought to have the Professional and Amateur Sports Protection Act (PASPA) overturned, allowing state-sponsored sports betting. The case, formerly titled Christie v. National Collegiate Athletic Association until Governor Chris Christie left office, was combined with NJ Thoroughbred Horsemen v. NCAA No. 16-477.
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Murphy v. Waterfront Commission of New York Harbor, 378 U.S. 52 (1964), was a United States Supreme Court case concerning the self-incrimination clause in the Fifth Amendment to the United States Constitution. The Court ruled that a state cannot compel a witness to provide testimony that may be incriminating under other State/Federal laws, even if it granted immunity under its own laws. Decided on the same day as Malloy v. Hogan (1964), the Supreme Court reconsidered its previous rulings that the Federal Government could compel witness testimony that could be incriminating under a state's laws, and states could similarly compel testimony that would be incriminating under Federal law.
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