United States v. Washington (2022)

Last updated

United States v. Washington
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued April 18, 2022
Decided June 21, 2022
Full case nameUnited States v. Washington, et al.
Docket no. 21-404
Citations596 U.S. ___ ( more )
Argument Oral argument
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Elena Kagan  · Neil Gorsuch
Brett Kavanaugh  · Amy Coney Barrett
Case opinion
MajorityBreyer, joined by unanimous

United States v. Washington, 596 U.S. ___ (2022), was a United States Supreme Court case dealing with workers' compensation laws at the federal and state level. The case revolved around compensation for non-federal employees working for nuclear and chemical cleanup on the Hanford Site in Washington State required under state law.

Contents

Background

The Hanford Site near the Tri-Cities in Washington state had formerly been used for the processing of nuclear materials for weapons during World War II, and then additional nuclear research during the Cold War. Nuclear and chemical material stored in underground tanks on site were found to leak into the environment including the Columbia River, and the site's major systems were decommissioned by 1971. By 1988, the site was designated as a Superfund cleanup site, and the United States Department of Energy (DOE) took over the site in 1989 to begin cleanup operations, bringing in several subcontractors to oversee and manage safe cleanup operations, an effort expected to run well throughout the 21st century. At the time of litigation, the site had about 400 federal employees and over 10,000 employees from non-federal contractors; over 100,000 people have worked on the Hanford Site over its history.

The federal employees were broadly covered under the Federal Employees' Compensation Act (FECA), but until 2018, the contract employees were covered by the Washington Industrial Insurance Act (WIIA); in either case, benefits are paid for by the DOE. WIIA is generally weaker than FECA, only providing compensation for employee illnesses that could be proven to have been a result of their occupation. An investigative report by KING-TV in February 2017 found that many of the non-federal employees that were likely exposed routinely to nuclear and chemical wastes at Harford were being denied compensation. [1] Washington's senators, Maria Cantwell and Patty Murray, requested the DOE examine the workers' compensation, and in a 2018 report, the DOE's Inspector General affirmed there was lapse of monitoring in how workers' compensation was handled. The DOE acknowledge that they had terminated their contract with Penser North America which did preliminary processing of these claims and were reasonable for denials. [2]

As a result of KING-TV's report, Washington's legislation passed HR 1723 in 2018, which specifically made a workers' compensation exemption for the Hanford Site; due to its high risk factor, HR 1723 established a lower threshold of showing presumption of illness caused by their occupation, comparable to FECA. However, such claims could still be denied by showing evidence of other external factors that could cause that illness, such as lifestyle choices or prior exposure at other jobs. Former and current employees at the site with presumed illnesses were eligible to apply for compensation, as long as these existed before the law was enacted in June 2018. [3]

The U.S. government argued the law improperly allowed the state to place an undue burden on the federal government, as the cost of covering the non-federal employees' compensation could be great. They sued the state in the United States District Court for the Eastern District of Washington, at the end of 2018, but Judge Stanley Bastian ruled in favor of the state by June 2019. Bastian stated in his opinion that "(Current federal law) gives Washington powers that include the ability to legislate…to address specific risks to employees in specific industries." [4] The government appealed to the Ninth Circuit but the three-judge panel unanimously upheld the district court's ruling in August 2020, [5] and denied rehearing en banc in April 2021, over the dissent of Judge Daniel P. Collins and three other judges. [6]

Supreme Court

The government petitioned to the Supreme Court to review the lower court's ruling. The government asked the Court to determine if there was intergovernmental immunity that prevented the state from placing certain obligations on the federal government, or if under 40 U.S.C.   § 3172(a), that the state could enact workers' compensation rights for work on the federal facility. The Court granted the case in January 2022. [7]

Prior to oral arguments, Washington amended its law with SB 5890 that expanded the presumption to all workers, not just federal contractors, that worked at a radiological hazardous waste facility within the state. The new law came into effect in March 2022, which the state argued in filings made the case moot since it no longer discriminated against the federal government. [8]

Oral arguments were held on April 18, 2022. [8]

Opinion of the Court

The case was decided on June 22, 2022. In a unanimous decision, the Supreme Court ruled that the Washington law violated the Supremacy Clause of the United States Constitution by discriminating against the federal government. [9]

In writing the unanimous opinion of the court, Justice Breyer wrote that the Washington law fell outside the scope of 40 U.S.C.   § 3172(a), since it discriminated in favor of federal employees and contractors and did not cover other workers employees in the state. Breyer wrote that only Congress may make such exemptions under the Supremacy Clause. He wrote that the law also made "causal presumption" about the various diseases and illness one might get while working at the Hanford site. [9]

Next, Justice Breyer addressed the point in which Washington state brought up, that the enactment of the new statute makes this case moot. The state argued that even if the federal government wins, they will not receive any compensation as the new statute would encompass the previous claims brought by the government. However, Justice Breyer contends that it is not "impossible" that the state would recover no compensation at all and therefore the case is not moot. [9]

Lastly, the court ruled that this law hinders the operations of the federal government and is not uniformly put up throughout the state, which goes against the court's "intergovernmental immunity doctrine" [9]

Related Research Articles

Hanford Site Decommissioned nuclear production complex in Washington, United States

The Hanford Site is a decommissioned nuclear production complex operated by the United States federal government on the Columbia River in Benton County in the U.S. state of Washington. The site has been known by many names, including Hanford Project, Hanford Works, Hanford Engineer Works and Hanford Nuclear Reservation.

Pacific Northwest National Laboratory Research institute

Pacific Northwest National Laboratory (PNNL) is one of the United States Department of Energy national laboratories, managed by the Department of Energy's (DOE) Office of Science. The main campus of the laboratory is in Richland, Washington.

Rocky Flats Plant Defunct American nuclear weapons manufacturing site

The Rocky Flats Plant was a U.S. manufacturing complex that produced nuclear weapons parts in the western United States, near Denver, Colorado. The facility's primary mission was the fabrication of plutonium pits, which were shipped to other facilities to be assembled into nuclear weapons. Operated from 1952 to 1992, the complex was under the control of the U.S. Atomic Energy Commission (AEC), succeeded by the Department of Energy (DOE) in 1977.

Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356 (2001), was a United States Supreme Court case about Congress's enforcement powers under the Fourteenth Amendment to the United States Constitution. The Supreme Court decided that Title I of the Americans with Disabilities Act was unconstitutional, insofar as it allowed states to be sued by private citizens for money damages.

Savannah River Site Nuclear reservation in the US

The Savannah River Site (SRS) is a U.S. Department of Energy (DOE) reservation in the United States in the state of South Carolina, located on land in Aiken, Allendale, and Barnwell counties adjacent to the Savannah River, 25 miles (40 km) southeast of Augusta, Georgia. The site was built during the 1950s to refine nuclear materials for deployment in nuclear weapons. It covers 310 square miles (800 km2) and employs more than 10,000 people.

Y-12 National Security Complex US Energy Dept facility in Oak Ridge, Tennessee

The Y-12 National Security Complex is a United States Department of Energy National Nuclear Security Administration facility located in Oak Ridge, Tennessee, near the Oak Ridge National Laboratory. It was built as part of the Manhattan Project for the purpose of enriching uranium for the first atomic bombs. It is considered the birthplace of the atomic bomb. In the years after World War II, it has been operated as a manufacturing facility for nuclear weapons components and related defense purposes.

Jacobs Engineering Group American engineering company

Jacobs Engineering Group Inc. is an American international technical professional services firm. The company provides engineering, technical, professional and construction services, as well as scientific and specialty consulting for a broad range of clients globally, including companies, organizations, and government agencies. Jacobs has consistently ranked No. 1 on both Engineering News-Record (ENR)'s 2018, 2019, 2020 & 2021 Top 500 Design Firms and Trenchless Technology’s 2018, 2019, 2020 & 2021 Top 50 Trenchless Engineering Firms. Its worldwide annual revenue reached over $14 billion in the 2021 fiscal year, and earnings rose to 477 million.

Radiation Exposure Compensation Act US law

The United States Radiation Exposure Compensation Act (RECA) is a federal statute providing for the monetary compensation of people, including atomic veterans, who contracted cancer and a number of other specified diseases as a direct result of their exposure to atmospheric nuclear testing undertaken by the United States during the Cold War, or their exposure to radon gas and other radioactive isotopes while undertaking uranium mining, milling or the transportation of ore.

Hazardous Waste Operations and Emergency Response is a set of guidelines produced and maintained by the Occupational Safety and Health Administration which regulates hazardous waste operations and emergency services in the United States and its territories. With these guidelines, the U.S. government regulates hazardous wastes and dangerous goods from inception to disposal.

Eastern Enterprises v. Apfel, 524 U.S. 498 (1998), is a United States Supreme Court case in which the Court held that the Coal Industry Retiree Health Benefit Act constituted an unconstitutional regulatory taking of property which required the Act to be invalidated. The import of this decision is that it was made in the context of a purely economic regulation. The plurality examines the statute and its resultant harm as an ad hoc factual inquiry based on factors delineated in Penn Central Transportation Co. v. New York City, such as the economic impact of the regulation, its interference with reasonable investment backed expectations, and the character of the governmental action. The decision thereby moved beyond the traditional notions of equal protection which had been applied to economic regulation since the time of Lochner v. New York, requiring extreme deference to Congress, and applied a regulatory takings analysis to the problem resulting in a much less deferential result. While the plurality recognizes that this is not a traditional takings case where the government appropriates private property for public use, they also state this is the type of case where the "Armstrong Principle" of preventing the government from forcing some people alone to bear public burdens which, in all fairness and justice, should be borne by the public as a whole. However, while the plurality seems to invalidate this particular law on takings grounds, the concurrences and the dissents warn of such an analysis as this should actually be examined under substantive due process or ex post facto theories.

The Energy Employees Occupational Illness Compensation Program Act (EEOICPA) was passed by Congress in 2000 and is designed to compensate individuals who worked in nuclear weapons production and as a result of occupational exposures contracted certain illnesses. EEOICPA was signed into law by President Bill Clinton on October 30, 2000.

In United States Constitutional Law, intergovernmental immunity is a doctrine that prevents the federal government and individual state governments from intruding on each other's sovereignty. It is also referred to as a Supremacy Clause immunity or simply federal immunity from state law.

Nuclear labor issues Radiation workers health and labor issues

Nuclear labor issues exist within the international nuclear power industry and the nuclear weapons production sector worldwide, impacting upon the lives and health of laborers, itinerant workers and their families.

Knox v. Service Employees International Union, 567 U.S. 298 (2012), is a United States constitutional law case. The United States Supreme Court held in a 7–2 decision that Dianne Knox and other non-members of the Service Employees International Union did not receive the required notice of a $12 million assessment the union charged them to raise money for the union's political fund. In a tighter 5–4 ruling, the court further held that the long-standing precedent, the First Amendment requirement that non-union members covered by union contracts be given the chance to "opt out" of special fees was insufficient. Setting new precedent, the majority ruled that non-members shall be sent notice giving them the option to opt into special fees.

Colorado Republican Federal Campaign Committee v. FEC, 518 U.S. 604 (1996), was a case heard by the Supreme Court of the United States in which the Colorado Republican Party challenged the Federal Election Commission (FEC) as to whether the "Party Expenditure Provision" of the Federal Election Campaign Act of 1971 (FECA) violated the First Amendment right to free speech. This provision put a limit on the amount of money a national party could spend on a congressional candidate's campaign. The FEC argued that the Committee violated this provision when purchasing a radio advertisement that attacked the likely candidate of the Colorado Democratic Party. The court held that since the expenditures by the Committee were made independently from a specific candidate, they did not violate the campaign contribution limitations established by the FECA, and were protected under the First Amendment.

Lane v. Franks, 573 U.S. 228 (2014), is a U.S. Supreme Court case involving public employee's freedom of speech rights. Edward Lane sued Steve Franks for unfairly firing him, out of retaliation for sworn testimony Lane gave during a federal fraud case. The Eleventh Circuit originally ruled in favor of Franks, “denying [Lane] first amendment protection to subpoenaed testimony”. The case was argued before the Supreme Court on April 28, 2014. The case was decided on June 19, 2014.

Davis v. Michigan, 489 U.S. 803 (1989), is a case in the Supreme Court of the United States holding that states may not tax federal pensions if they exempt their own state pensions from taxation. In the 1930s, the federal and state governments began to charge income tax on salaries paid to each other's employees. However, reciprocal treatment was required under the doctrine of intergovernmental immunity. The Court's ruling extended the reciprocity to pensions, since they are a form of deferred compensation for services previously rendered by an employee.

Workers' compensation in the United States is a primarily state-based system of workers' compensation.

Torres v. Texas Department of Public Safety, 597 U.S. ___ (2022), was a United States Supreme Court case dealing with the Uniformed Services Employment and Re-employment Rights Act of 1994 (USERRA) and state sovereign immunity. In a 5–4 decision issued in June 2022, the Court ruled that state sovereign immunity does not prevent the state from being sued under federal law related to the nation's defense.

References

  1. ↑ Frame, Susannah (February 3, 2017). "Sick and denied care at Hanford: 'We want our lives back'". KING-TV . Retrieved January 10, 2022.
  2. ↑ Sundell, Allison; Frame, Susannah (August 23, 2019). "Hanford workers' comp program fails sick employees, report finds". KING-TV . Retrieved January 10, 2022.
  3. ↑ Cary, Annette (March 7, 2018). "Help on the way for ill Hanford workers". Tri-City Herald . Retrieved January 10, 2022.
  4. ↑ Frame, Susannah (June 13, 2019). "Washington state prevails over DOJ in Hanford workers' comp lawsuit". KING-TV . Retrieved January 10, 2022.
  5. ↑ Frame, Susannah (August 19, 2020). "Federal judges uphold state law aimed at helping sick Hanford workers". KING-TV . Retrieved January 10, 2022.
  6. ↑ Alsup, Maeve (April 16, 2021). "Washington Avoids Further Review of Tweak to Workers' Comp Law". Bloomberg Law . Retrieved January 10, 2022.
  7. ↑ Mulvaney, Erin (January 10, 2022). "High Court Takes Up Nuclear Site Workers' Compensation Case". Bloomberg Law . Retrieved January 10, 2022.
  8. 1 2 "Justices wrestle with mootness and intergovernmental immunity in Hanford workers' comp case". April 20, 2022.
  9. 1 2 3 4 Duff, Michael C. (June 22, 2022). "Justices overturn Washington workers' compensation law on a strict reading of intergovernmental immunity". SCOTUSBlog . Retrieved June 25, 2022.
This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.