Kassel v. Consolidated Freightways

Brief Fact Summary.

Appellee Consolidated challenged an Iowa statute that prohibits the use of certain large trucks within the State alleging that it unconstitutionally burdens interstate commerce.

Synopsis of Rule of Law.

The Commerce Clause does not invalidate all state restrictions on commerce. Those who would challenge such bona fide safety regulations must overcome a strong presumption of validity.

Facts.

Appellee Consolidated Freightways Corporation of Delaware is one of the largest common carriers in the country. Consolidated would like to use 65-foot doubles on many of its trips through Iowa. The State of Iowa, however, by statute restricts the length of vehicles that may use its highways. Unlike all other States in the West and Midwest, Iowa generally prohibits the use of 65-foot doubles within its borders. Instead, most truck combinations are restricted to 55 feet in length. Despite these restrictions, Iowa’s statute permits cities abutting the state line by local ordinance to adopt the length limitations of the adjoining State. Where a city has exercised this option, otherwise oversized trucks are permitted within the city limits and in nearby commercial zones. Because of Iowa’s statutory scheme, Consodliated cannot use its 65-foot doubles to move commodities through the State.

Issue.

Does an Iowa statute that prohibits the use of certain large trucks within the State unconstitutionally burdens interstate commerce?

Held.

Yes, the Iowa truck-length limitations unconstitutionally burden interstate commerce, because the regulation, designed for the salutary purpose, does further the purpose so marginally, and interfere with commerce so substantially, as to be invalid under the Commerce Clause. Iowa had failed to present any persuasive evidence that 65-foot doubles are less safe than 55-foot singles. Also, Iowa’s law is out of step with the laws of all other Midwestern and Western States. Iowa thus unconstitutionally burdens the interstate flow of goods by ruck.

Dissent.

Justice Rehnquist

Whenever a State enacts more stringent safety measures than its neighbors, in an area which affects commerce, the safety law will have the incidental effect of deflecting interstate commerce to the neighboring States. The safety and protectionist motives cannot be separated: The whole purpose of safety regulation of vehicles is to protect the State from unsafe vehicles. The true problem with today’s decision is that it gives no guidance whatsoever to those States as to whether their laws are valid or how to defend them. The decision gives no guidance to Consolidated or other trucking firms either.

Discussion.

Consolidated demonstrated that Iowa’s law substantially burdens interstate commerce. Trucking companies that wish to continue to use 65-foot doubles must route them around Iowa or detach the trailers of the doubles and ship them through separately. Alternatively, trucking companies must use the smaller 55-foot singles or 60-foot doubles permitted under Iowa law. Each of these options endangers inefficiency and added expense. In addition to increasing the costs of the trucking companies, Iowa’s law may aggravate, rather than ameliorate, the problem of highway accidents. Either more small trucks must be used to carry the same quantity of goods through Iowa, or the same number of large trucks must drive longer distances to bypass Iowa. Other things being equal, accidents are proportional to distance traveled. Iowa may not shunt off its fair of the burden of maintaining interstate truck routs, nor may it create increased hazards on the highways of neighboring States in order to decrease the hazards on Iowa highways.