In the 1977 case Ray, Governor of Washington, et al. v. Atlantic Richfield Co. et al., the U.S Supreme Court was tasked with determining whether a state could regulate oil tanker design and operation in its waters beyond federal standards without violating the Supremacy Clause or Commerce Clause of the Constitution. The State of Washington had enacted legislation requiring certain safety measures for tankers operating in Puget Sound that exceeded federal requirements, which Atlantic Richfield Company challenged as unconstitutional interference with interstate commerce and preemption by federal law. The court ruled 6-3 in favor of Governor Dixy Lee Ray and other appellants representing Washington State's interests, upholding states' rights to impose additional regulations on maritime activities within their jurisdiction if they are designed to protect environmental resources from potential harm caused by oil spills or similar disasters. This decision affirmed that while Congress has broad authority over navigable waters under its Commerce Clause powers, it does not prevent states from exercising their police powers to safeguard local environments unless there is clear evidence Congress intended such preemption.

In the dissenting opinion for Ray, Governor of Washington, et al. v. Atlantic Richfield Co. et al., Justice Brennan disagreed with the majority's interpretation of the Rivers and Harbors Appropriation Act of 1899 (RHA). He argued that Congress intended to give states a role in regulating water pollution under this act and that it was not meant to be exclusively federal jurisdiction as suggested by the majority ruling. Furthermore, he contended that there was no conflict between state law and RHA because both aimed at preventing water pollution; hence they could coexist harmoniously without one preempting or invalidating the other. The justice also expressed concern over potential negative environmental impacts if states were barred from imposing stricter regulations than those set by federal standards.