the states while encroaching on the supremacy of the United States. The Waterfront Commission Act does seem to be such an agreement. Waterfront governance is closely related, to interstate and foreign commerce, and unquestionably impinges on the supremacy of the federal government. Cf American Sugar Refining Co., 55 N.Y.2d 11, 447 N.Y.S.2d 685, 432 N.E.2d 578. The second issue is whether Congress actually consented to the Waterfront Commission Act. The Constitution does not specify how and when Congressional consent is given to a compact. Generally, the form of consent is left to the discretion of Congress. Actual consent may be express or implied, and may be given before or after the states enter into the agreement. See Cuyler v. Adams, 449 U.S. at 441 & n. 9, 101 S.Ct. at 708 & n. 9 (<HOLDING>); Virginia v. Tennessee, 148 U.S. at 521, 13
holding there is no consent as a matter of law where the consent was given under coercion holding that because consent is not a statement and a request for consent is not an interrogation giving consent to search is a neutral fact which has no tendency to show that the suspect is guilty of any crime holding that congress by enacting the crime control consent act of 1934 gave consent in advance to the interstate agreement on detainers initially drafted by the council of state governments in 1956 recognizing that consent is an exception to the warrant requirement and that voluntariness of consent depends on the totality of the circumstances holding under state constitution that validity of consent search requires knowledge of right to refuse consent