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.