Loren J. Pike v. Bruce Church, Inc

Brief Fact Summary. The Plaintiff, Bruce Church, Inc. (Plaintiff) challenged a law enacted by the Defendant, state of Arizona (Defendant) that prevented the transportation of uncrated cantaloupes within the State. The Plaintiff sued arguing that the law violated the Commerce Clause of the United States Constitution (Constitution)

Synopsis of Rule of Law. Where a state statute regulates even-handedly to effectuate a legitimate local public interest and its effects on interstate commerce are only incidental, it will be upheld unless the burden imposed on such commerce is clearly excessive in relation to the putative local benefits.

Facts. An Arizona law requires that all cantaloupes grown in Arizona and offered for sale must be packed in closed standard containers approved by government officials. Loren Pike, the Defendant state’s official in charge of enforcing the law, issued an order prohibiting the Plaintiff, a cantaloupe farming company, from transporting uncrated cantaloupes from their Arizona ranch to the California packing place. The closest available packing shed to the Defendant state was California and calculated they would suffer $700,000 in losses unless the order was enjoined.
The Plaintiff filed suit in district court to enjoin the order on the ground that it was unconstitutional because it violated the Constitution’s Commerce Clause.

Issue. Can a nondiscriminatory state law violate the dormant Commerce Clause?

Held. Yes, the Supreme Court of the United States (Supreme Court) developed a test for determining whether nondiscriminatory state laws violate the dormant commerce clause. Where a nondiscriminatory law effectuates a legitimate local interest and its effects on interstate commerce are only incidental, it will be upheld unless the burden imposed on interstate commerce is clearly excessive in relation to the putative local benefits. Where there is a legitimate local interest it must be measured against the burden it composes.

Discussion. The purpose of the law in question here was to protect and enhance the reputation of growers within the State, a legitimate State interest. However, the State’s interest is not worth the Arizona cantaloupe company building and operating a new $200,000 packing plant.