New York v. New Jersey, 598 U.S. 218

In 1953 New York and New Jersey, with Congress's approval, enacted the Waterfront Commission Compact creating the Waterfront Commission of New York Harbor, a bistate agency vested with regulatory and law-enforcement authority at the Port.
The Compact requires both States to agree to amendments and recognizes Congress’s power to alter or repeal it, but is silent about unilateral withdrawal or termination.
Over decades the Port’s activity shifted toward New Jersey, and New Jersey concluded the Commission was outdated; in 2018 New Jersey passed a statute to withdraw and dissolve the Commission.
The Commission sued to stop withdrawal; a district court barred withdrawal, but the Third Circuit dismissed the Commission’s suit on sovereign-immunity grounds.
The Supreme Court granted leave, considered cross-motions for judgment on the pleadings, and held New Jersey may unilaterally withdraw based on background contract principles and state-sovereignty considerations.

Issue	Plaintiff's Argument (New York)	Defendant's Argument (New Jersey)	Held
Whether a State may unilaterally withdraw from the Waterfront Commission Compact	The Compact should be read to prohibit unilateral withdrawal; termination requires mutual consent or congressional action	The Compact is silent; default contract-law rule allows termination at will for indefinite, ongoing performance	New Jersey may unilaterally withdraw
What interpretive rule applies when a compact is silent on withdrawal	Historical compacts show silence meant prohibition; States would have said so if withdrawal allowed	Use background principles of contract law; ongoing indefinite agreements are terminable at will	Applied default contract-law rule permitting withdrawal for ongoing, indefinite compacts
Do analogies to international treaty law or prior interstate practice bar withdrawal	International treaty practice and decades of dispute-resolution between the States imply withdrawal is improper	Treaty analogies are equivocal; past cooperative practice doesn’t prove a prohibition on withdrawal	Rejected treaty and practice arguments as unpersuasive
Scope of the ruling for other interstate compacts	Allowing withdrawal will broadly unsettle compacts	Decision is limited to compacts silent on withdrawal that exclusively require ongoing indefinite performance; boundary/water-rights/property compacts differ	Ruling limited; States can draft express withdrawal clauses

Cuyler v. Adams, 449 U.S. 433 (federal-question review of interstate compact interpretation)
Tarrant Regional Water Dist. v. Herrmann, 569 U.S. 614 (begin compact interpretation with express terms; compacts construed as contracts)
New Jersey v. New York, 523 U.S. 767 (background contract principles applied to interstate compacts)
Alabama v. North Carolina, 560 U.S. 330 (compact is both a contract and a federal statute; federal law can preempt contrary state law)
Texas v. New Mexico, 482 U.S. 124 (compacts construed under contract-law principles)
Green v. Biddle, 8 Wheat. 1 (early precedent on interstate compacts)
Compania Embotelladora Del Pacifico v. Pepsi Cola Co., 976 F.3d 239 (application of contract termination for indefinite agreements)
Delta Servs. & Equip., Inc. v. Ryko Mfg. Co., 908 F.2d 7 (parties need not continue performance when relationship has soured)