U.S. Supreme Court
Rose v. Arkansas State Police, 479 U.S. 1 (1986)
Rose v. Arkansas State Police
Decided Nov. 3, 1986
479 U.S. 1
After an Arkansas State Trooper was killed in the line of duty, his widow (petitioner) received a $50,000 benefit from the Federal Government pursuant to the Public Safety Officers' Death Benefits Act. The Act provides that its benefits "shall be in addition to any other benefit that may be due from any other source," with certain exceptions not applicable here. Petitioner also applied for death benefits under the Arkansas Workers' Compensation Act, which contains a provision (enacted three years after the federal Benefits Act) stating that benefits under the State Act shall be reduced by the amount of any federal payment under "an Act of Congress providing benefits for public safety officers." State administrative proceedings instituted by petitioner ultimately resulted in the rejection of her claim that her state benefits should not be offset by the federal payment. It was held that there was no inconsistency between the state and federal laws, and thus that the state statute need not give way under the Supremacy Clause of the Federal Constitution. The Arkansas Court of Appeals affirmed.
Held: The Arkansas statute authorizes the precise conduct that Congress sought to prohibit, and consequently is repugnant to the Supremacy Clause. The conflict between the Arkansas law and the federal Benefits Act is clear from the language of the statutes. The state court's reasoning that the federal law did not alter the States' traditional right to set the level of workers' compensation benefits misses the point. The Benefits Act does not require a State to set a particular benefit level for its chanroblesvirtualawlibrary
citizens; it simply prohibits a State from reducing the compensation it otherwise would provide to account for the federal payment. This reading of the Benefits Act is consistent with the legislative history, that shows that Congress was concerned about the inadequacy of death benefits paid to police officers by some States. Richardson v. Belcher, 404 U. S. 78, distinguished.
Certiorari granted; 16 Ark.App. 96, 697 S.W.2d 927, reversed and remanded.