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South Carolina State Highway Department v. Barnwell Brothers, Inc.

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Brief Fact Summary.

The respondent challenged the state act of South Carolina that prohibits use on the state highways of motor trucks and “semi-trailer motor trucks” whose width exceeds 90 inches and whose weight exceeds 20,000 pounds.

Synopsis of Rule of Law.

A state may impose non-discriminatory restrictions with respect to the character of motor vehicles moving in interstate commerce as a safety measure and as a means of securing the economical use of its highways.

Points of Law - Legal Principles in this Case for Law Students.

Hence, in reviewing the present determination we examine the record, not to see whether the findings of the court below are supported by evidence, but to ascertain upon the whole record whether it is possible to say that the legislative choice is without rational basis.

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Facts.

The South Carolina enacted an Act that prohibits use on the state highways of motor trucks and “semi-trailer motor trucks” whose width exceeds 90 inches and whose weight exceeds 20,000 pounds. The trial court held the statute unconstitutional upon its finding that there is a large amount of motor truck traffic passing over the highways of South Carolina and that the statute would unreasonably burden the interstate commerce.

Issue.

Does the South Carolina Act that prohibits use on the state highways of motor trucks and “semi-trailer motor trucks” whose width exceeds 90 inches and whose weight exceeds 20,000 pounds violate the Constitution?

Held.

No, the regulatory measures taken by South Carolina are within its legislative power and the Act produces no unreasonable burden on interstate commerce and thus it does not infringe the Constitution.

Discussion.

A state commission recommended the present weight limitation after a full consideration of relevant data, including a report by the state engineer who constructed the highways of the state and advised a lower limitation as necessary for their preservation. The respondent’s argument that many states have adopted a different standard and therefore the South Carolina’s another distinct standard would put burden on truck drivers is not persuasive. The conditions under which highways are built in different states are not uniform. The road building art is far from having attained a scientific certainty and the legislature, being free to exercise its own judgment, is not bound by that of other legislatures.


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