Pike v. Bruce Church, Inc., 397 U.S. 137 (1970)
Even if a law does not discriminate on its face against interstate commerce, it is not permissible if the burdens greatly exceed the benefits to local commerce.
Bruce Church, Inc. was an agricultural company that operated in California and Arizona. It sent the cantaloupes that it cultivated in Arizona to its packing facilities in California, which were 30 miles away. The cantaloupes were sent in bulk and were not packed in crates. This method clashed with an Arizona law that required all cantaloupes grown in the state to be packed there before leaving it. Pike, who was responsible for enforcing the law, ordered Bruce Church to cease using its current transportation method.
Bruce Church argued that the law violated the Dormant Commerce Clause doctrine by imposing a burden on interstate commerce. It claimed that it would need to spend $200,000 to build and operate a packing facility in Arizona in order to comply with the law. The lower court granted an injunction against the enforcement of the law.
- Potter Stewart (Author)
- Warren Earl Burger
- Hugo Lafayette Black
- William Orville Douglas
- John Marshall Harlan II
- William Joseph Brennan, Jr.
- Byron Raymond White
- Thurgood Marshall
The state has a legitimate interest in protecting and furthering the reputation of its growers. However, a law supporting that interest still must be balanced against the burdens on interstate commerce that result. Requiring a company to perform operations in a home state that could be performed more efficiently elsewhere is likely to trigger concern under the Dormant Commerce Clause. The expenditures that would be imposed on the company in building an otherwise unnecessary facility are out of proportion to the minor state interest in enhancing the reputation of its growers by having their origin marked on their fruit.Case Commentary
While the state is justified in trying to enhance the reputation of its canteloupe growers, requiring them to build and operate a new plant specifically to comply with the rule is an excessive burden.
U.S. Supreme CourtPike v. Bruce Church, Inc., 397 U.S. 137 (1970)
Pike v. Bruce Church, Inc.
Argued January 13, 1970
Decided March 2, 1970
397 U.S. 137
Appellee company grows cantaloupes of superior quality in Parker, Arizona. Since the company lacks packing sheds in Parker, it transports the cantaloupes to its nearby facilities in California, where they are sorted, inspected, packed, and shipped in containers that bear the name of the California packer. Appellant official, acting under the Arizona Fruit and Vegetable Standardization Act, which is designed to prevent deceptive packaging, entered an order prohibiting the company from shipping its cantaloupes outside the State unless they were packed in containers in a manner approved by appellant. Appellant contends that his order is necessary to ensure that the cantaloupes be identified as of Arizona origin. Appellee brought this suit for injunctive relief challenging the constitutionality of the order, which would have the effect of requiring appellee to build packing facilities in or near Parker at a cost of about $200,000. A three-judge District Court issued an injunction holding that the order constituted an unlawful burden on interstate commerce.
1. Appellant's order burdens interstate commerce, since the cantaloupes were destined to be shipped from Arizona to an ascertainable location in California immediately after harvest, and application of the challenged statute would require an operation now conducted outside the State to be performed within the State so it can be regulated there. Pp. 397 U. S. 140-142.
2. The burden on interstate commerce imposed by appellant's order is unconstitutional, since Arizona's minimal interest in identifying the origin of appellee's cantaloupes to enhance the reputation of Arizona producers cannot justify subjecting appellee to the substantial capital expenditure of building and operating in Arizona a packing plant that it does not need. Pp. 397 U. S. 142-146.