Friday, September 21, 2012

Hunt v. Washington State Apple Adver. Comm'n, 432 U.S. 333, 97 S. Ct. 2434, 53 L. Ed. 2d 383 (U.S.N.C. 1977)



Facts
The Washington State Apple Advertising Commission brought action seeking declaratory and injunctive relief and challenging the constitutionality of North Carolina statute which in effect prohibits the display of Washington State apple grades on closed containers shipped into the state.
A Three-Judge District Court, granted the requested relief, and defendants appealed.

Holdings
The Supreme Court held that:
  1. the Commission's status as a state agency, rather than a traditional voluntary membership organization, did not preclude it from asserting, in a representational capacity, claims of Washington apple growers and dealers who formed its constituency, notwithstanding that “membership” was “compelled” in the form of mandatory assessments; 
  2. record, including sales volume and compliance costs among other matters, precluded conclusion “to a legal certainty” that such losses and expenses would not, if they had not done so already, amount to the requisite $10,000 for at least some of individual growers and dealers and thus jurisdictional requirement of $10,000 in controversy was met, and 
  3. challenged statute violates commerce clause insofar as it prohibits the display of Washington State grades even if enacted for the declared purpose of protecting consumers from deception and fraud in the market place.
Affirmed.

Thursday, September 20, 2012

S.-Cent. Timber Dev., Inc. v. Wunnicke, 467 U.S. 82, 104 S. Ct. 2237, 81 L. Ed. 2d 71 (1984)



Facts
Alaskan timber purchaser and shipper brought action challenging Alaska's requirement that timber taken from state lands be processed within the state prior to export. 
The U.S. District Court found the requirement violative of the commerce clause, and Alaska appealed. 
The Court of Appeals reversed. Certiorari was granted. 

Holdings
The Supreme Court held that the requirement was not authorized by Congress' policy with respect to timber taken from federal land where application of that policy to state lands was not expressly stated.
Reversed and remanded.

Wednesday, September 19, 2012

W. Lynn Creamery, Inc. v. Healy, 512 U.S. 186, 114 S. Ct. 2205, 129 L. Ed. 2d 157 (1994)



Facts
Massachusetts milk dealers brought suit challenging milk pricing order as violating commerce clause, and their licenses were revoked by the Massachusetts Department of Food and Agriculture based on their failure to comply with provisions of the order.
The Supreme Judicial Court affirmed, and certiorari was granted.

Holdings
The Supreme Court held that Massachusetts milk pricing order, which subjected all fluid milk sold by dealers to Massachusetts retailers to assessment, with entire assessment distributed to Massachusetts dairy farmers, violated commerce clause.
Reversed.


Tuesday, September 18, 2012

Dean Milk Co. v. City of Madison, Wis., 340 U.S. 349, 71 S. Ct. 295, 95 L. Ed. 329 (1951)



Facts
Action by the Dean Milk Company against the City of Madison, Wisconsin, and others, for a declaratory judgment as to the validity of two sections of an ordinance prohibiting the sale of milk unless bottled within five miles from the central square of Madison, and relieving municipal authorities from duty to inspect farms located beyond 25 miles from center of the city.
The Supreme Court of Wisconsin affirmed a judgment of the Circuit Court for Dane County,  upholding the ordinance, and plaintiff appealed. 

Holding
The Supreme Court held that the five-mile provision unduly burdened interstate commerce in view of the availability of reasonable and adequate alternatives.
Judgment vacated and cause remanded for further proceedings.


Monday, September 17, 2012

United Haulers Ass'n, Inc. v. Oneida-Herkimer Solid Waste Mgmt. Auth., 550 U.S. 330, 127 S. Ct. 1786, 167 L. Ed. 2d 655 (2007)



Facts: 
Solid waste management companies and association representing their interests brought § 1983 action against counties and their solid waste management authority, alleging that counties' flow ordinances regulating the collection, processing, transfer, and disposal of all solid waste within counties violated the Commerce Clause. 
The U.S. District Court granted summary judgment in favor of plaintiffs, and counties appealed. 
The Second Circuit reversed and remanded. 
On remand, the U.S. District Court entered summary judgment in favor of defendants, and plaintiffs appealed. 
The Court of Appeals affirmed. 
Certiorari was granted.

Holdings: 
The U.S. Supreme Court held that:

  1. county flow control ordinances that favored state-created public benefit corporation, by requiring businesses hauling waste in counties to bring waste to facilities owned and operated by this public benefit corporation, but that treated every private business, whether in-state or out-of-state, in exactly the same way, did not discriminate against interstate commerce in violation of “dormant” aspect of Commerce Clause; and 
  2. any incidental burden on interstate commerce that resulted from application of county flow control ordinances was not clearly excessive in relation to public benefits provided, in form of increased recycling.

Affirmed.