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:
- 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
- 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.
