Kassel v. Consolidated Freightways Corp

Brief Fact Summary.

Iowa passed a law prohibiting the use of 65-foot doubles, a type of truck, within its borders, but made exceptions for those trucks when they benefitted Iowa residents.

Synopsis of Rule of Law.

State regulations that only inconsequentially promote the public health or safety and interfere with interstate commerce substantially may be invalid under the Commerce Clause.

Facts.

Iowa passed a law prohibiting the use of 65-foot doubles, a type of truck, within its borders, but made exceptions for those trucks when they benefitted Iowa residents. The Plaintiff filed suit, arguing that Iowa’s scheme unconstitutionally burdened interstate commerce. Iowa claimed that it enacted its scheme lawfully for the purpose of promoting local safety.

Issue.

Does the Iowa statute that prohibits the use of certain large trucks within the state violate the Commerce Clause?

Held.

Yes, the Iowa statute that prohibits the use of certain large trucks within the state violates the Commerce Clause.

Dissent.

Justice Rehnquist

A determination that a state law is a rational safety measure does not end the Commerce Clause inquiry. Moreover, it is not the function of this Court to form public policy, which is a function of the state legislature. But that is what the Court is doing when it balances incremental safety benefits between various types of trucks.

Concurrence.

Justice Brennan

Although Iowa’s lawyers in this litigation have defended this regulation on the basis of the safety advantages of the different types of trucks at issue, Iowa’s actual rationale for maintaining the regulation had nothing to do with these purported safety differences. In actuality, Iowa enacted this regulation with the express intent of discouraging interstate truck traffic on Iowa’s highways. As such, the state’s actual purpose in maintaining this regulation is protectionist in nature and thus impermissible under the Commerce Clause.

Discussion.

In general, the Court accords special deference to state highway safety regulations. However, here the Court held that the law violated the Commerce Clause because Iowa presented no evidence that the 65-foot doubles were less safe than other trucks. As such, the safety justifications were illusory. Because Iowa imposed a burden on interstate commerce without any significant countervailing safety interest, its statute violates the Commerce Clause.