Facts of the Case

A California law dictated that before additional nuclear power plants could be built, the state energy commission had to determine that there would be adequate storage capacity for spent fuel rods. Two utility companies challenged the law, arguing that its provisions had been preempted by the federal Atomic Energy Act of 1954.

Question

Did the California law unconstitutionally intrude into areas of federal authority as defined by the Atomic Energy Act?

Conclusion

In a unanimous decision, the Court held that the California law did not impinge upon congressional authority. The Court found that because the rationale for enacting the law was an economic one, it did not interfere with federal regulations governing nuclear safety. The Court held that Congress had left "sufficient authority in the states to allow the development of nuclear power to be slowed or even stopped for economic reasons" and that the courts should not rework the division of regulatory authority created by Congress.