Hencely v. Fluor Corp.
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Hencely v. Fluor Corp. and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Hencely v. Fluor Corp..
The Supreme Court reviewed whether state-law tort claims against military contractors are preempted by federal law in the context of wartime activities. The Court found that the Fourth Circuit erred in preempting Hencely's claims, as the Federal Government did not authorize Fluor's conduct. The case was vacated and remanded for further proceedings.
Holding
The single most important “bottom line” of what the Court decided in Hencely v. Fluor Corp..
The Court held that the Fourth Circuit erred in finding Hencely’s state-law tort claims preempted where the Federal Government neither ordered nor authorized Fluor’s challenged conduct.
Constitutional Concepts
These are the Constitution-related themes that appear in Hencely v. Fluor Corp.. Click a concept to see other cases that involve the same idea.
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Why Preemption is relevant to Hencely v. Fluor Corp.
The Court's holding focused on whether federal law preempts state-law tort claims against military contractors.
Syllabus excerpt (verbatim)Held: The Fourth Circuit erred in finding Hencely’s state-law tort claims preempted where the Federal Government neither ordered nor authorized Fluor’s challenged conduct.
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Why State–Federal Power is relevant to Hencely v. Fluor Corp.
The case involves the allocation of authority between state tort law and federal military interests.
Syllabus excerpt (verbatim)Even assuming a 'uniquely federal interest' in regulating military bases overseas, no 'significant conflict' exists between that interest and state-law negligence liability based on a contractor’s departure from military instructions.
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Why Judicial Review is relevant to Hencely v. Fluor Corp.
The Court exercised its power to review and invalidate the Fourth Circuit's decision on preemption.
Syllabus excerpt (verbatim)The Fourth Circuit’s preemption test sweeps too broadly.
Key Quotes
Short excerpts from the syllabus in Hencely v. Fluor Corp. that support the summary and concepts above.
The Fourth Circuit erred in finding Hencely’s state-law tort claims preempted where the Federal Government neither ordered nor authorized Fluor’s challenged conduct.
Boyle’s rationale justifies no such blanket preemption.
Absent a statute to the contrary, States can regulate or tax federal contractors on the same terms as any private company.