Kassel v. Consolidated Freightways Corp., 450 U.S. 662 (1981)
State safety regulations cannot hinder interstate commerce more substantially than they promote their own goals.
A state law in Iowa provided that vehicles longer than 55 feet could not travel on its highways, unless they were trucks pulling two trailers, in which case a 60-foot limit was imposed. No other state in the western or midwestern regions of the country prohibited the use of 65-foot vehicles that were trucks pulling two trailers. Consolidated Freightways Corp. argued that this law thus created an undue burden on interstate commerce, and the lower courts agreed.Opinions
- Lewis Franklin Powell, Jr. (Author)
- Byron Raymond White
- Harry Andrew Blackmun
- John Paul Stevens
A strong presumption of validity attaches to state safety regulations that are made in good faith, but the presumption can be overcome. The state failed to show why 65-foot double trailers posed greater dangers than the 55-foot single trailers that the regulation permitted. On the other hand, the law creates a substantial burden on interstate commerce because it requires common carriers to use smaller trucks for routes going through the state or to route all of their larger trucks outside the state.
- William Hubbs Rehnquist (Author)
- Warren Earl Burger
- Potter Stewart
More weight should have been given to the presumption of validity for a state safety regulation. It may be struck down as unconstitutional only if its stated purpose is a pretext for discrimination against interstate commerce. The evidence does not show that this law is a pretext, so it should be upheld as constitutional.
- William Joseph Brennan, Jr. (Author)
- Thurgood Marshall
This application of the dormant Commerce Clause balanced the benefits that the law gained for the state against the burdens that it placed on interstate commerce by impeding the operations of trucking companies.
U.S. Supreme CourtKassel v. Consolidated Freightways Corp., 450 U.S. 662 (1981)
Kassel v. Consolidated Freightways Corporation of Delaware
Argued November 4, 1980
Decided March 24, 1981
450 U.S. 662
Unlike all other States in the West and Midwest, Iowa, by statute, generally prohibits the use of 65-foot double-trailer trucks within its borders, allowing the use of 55-foot single-trailer trucks and 60-foot double-trailer trucks. Appellee, a trucking company which carries commodities through Iowa on interstate highways, filed suit alleging that Iowa's statutory scheme unconstitutionally burdens interstate commerce. Because appellee cannot use its 65-foot doubles to move goods through Iowa, it must either use shorter truck units, detach the trailers of a 65-foot double and shuttle each through Iowa separately, or divert 65-foot doubles around Iowa. Iowa defended the law as a reasonable safety measure, asserting that 65-foot doubles are more dangerous than 55-foot singles and that, in any event, the law promotes safety and reduces road wear within the State by diverting much truck traffic to other States. The District Court found that the evidence established that 65-foot doubles were as safe as the shorter truck units, and held that the state law impermissibly burdened interstate commerce. The Court of Appeals affirmed.
Held: The judgment is affirmed. Pp. 450 U. S. 669-679; 450 U. S. 679-687.
612 F.2d 1064, affirmed.
JUSTICE POWELL, joined by JUSTICE WHITE, JUSTICE BLACKMUN, and JUSTICE STEVENS, concluded that the Iowa truck length limitations unconstitutionally burden interstate commerce. See Raymond Motor Transportation, Inc. v. Rice, 434 U. S. 429. Pp. 450 U. S. 669-679.
(a) The Commerce Clause itself, even without congressional implementation, is a limitation upon state power to regulate commerce. While "the Court has been most reluctant to invalidate" state regulations that touch upon safety -- especially highway safety -- the constitutionality of such regulations nevertheless depends on
"a sensitive consideration of the weight and nature of the state regulatory concern in light of the extent of the burden imposed on the course of interstate commerce."
Raymond, supra at 434 U. S. 443, 441. Pp. 450 U. S. 669-671.
(b) Since Iowa's safety interest has not been demonstrated, and since its regulations impair significantly the federal interest in efficient and
safe interstate transportation, the Iowa law cannot be harmonized with the Commerce Clause. The record, including statistical studies, supports the District Court's finding that 65-foot doubles are as safe as 55-foot singles. And appellee demonstrated that Iowa's law substantially burdens interstate commerce. In addition to the increased costs of trucking companies in routing 65-foot doubles around Iowa or using smaller truck units through the State, Iowa's law may aggravate, rather than ameliorate, the problem of highway accidents. Iowa's restriction -- resulting in either more smaller trucks being driven through Iowa or the same number of larger trucks being driven longer distances to bypass Iowa -- requires more highway miles to be driven to transport the same quantity of goods. Other things being equal, accidents are proportional to distance traveled. Thus, if 65-foot doubles are as safe as 55-foot singles, Iowa's law tends to increase the number of accidents, and to shift their incidence from Iowa to other States. Pp. 450 U. S. 671-675.
(c) While the Court normally accords "special deference" to a state legislature's judgment in enacting highway regulations, Raymond, supra, at 434 U. S. 444, n. 18, less deference is due where, as here, the local regulation bears disproportionately on out-of-state residents and businesses. Exemptions in Iowa's statutory scheme -- particularly those permitting single-trailer trucks hauling livestock or farm vehicles to be as long as 60 feet, and permitting cities abutting other States to enact local ordinances to adopt the larger length limitation of the neighboring State, and thus allow otherwise oversized trucks within the city limits and in nearby commercial zones -- secure to Iowans many of the benefits of large trucks while shunting to neighboring States many of the costs associated with their use. Moreover, the history of the "border cities exemption" suggests that Iowa's statute may not have been designed to ban dangerous trucks, but rather to discourage interstate truck traffic. A State cannot constitutionally promote its own parochial interests by requiring safe vehicles to detour around it. Pp. 450 U. S. 675-678.
JUSTICE BRENNAN, joined by JUSTICE MARSHALL, concluded that, in considering a Commerce Clause challenge to a state regulation, the judicial task is to balance the burden imposed on commerce against the local benefits sought to be achieved by the State's lawmakers. It is not the function of the court to decide whether, in fact, the regulation promotes its intended purpose, so long as an examination of the evidence before or available to the lawmaker indicates that the regulation is not wholly irrational in light of its purposes. Here, the safety advantages and disadvantages of the different types and lengths of trucks involved need not be analyzed, since the record and the legislative history of the Iowa regulation establish that those differences were irrelevant to Iowa's decision to maintain its regulation. Rather, Iowa
sought to discourage interstate truck traffic on its highways. This purpose, being protectionist in nature, is impermissible under the Commerce Clause. Iowa may not shunt off its fair share of the burden of maintaining interstate truck routes, nor may it create increased hazards on the highways of neighboring States in order to decrease the hazards on Iowa highways. Pp. 450 U. S. 679-687.
POWELL, J., announced the judgment of the Court and delivered an opinion, in which WHITE, BLACKMUN, and STEVENS, JJ., joined. BRENNAN, J., filed an opinion concurring in the judgment, in which MARSHALL, J., joined, post, p. 450 U. S. 679. REHNQUIST, J., filed a dissenting opinion, in which BURGER, C.J., and STEWART J., joined, post, p. 450 U. S. 687.