Brief Fact Summary. North Carolina adopted a statute requiring all containers of apples shipped into the state display “no grade other than the applicable U.S. grade or standard.” Washington state apple growers challenged the statute as an unreasonable burden on interstate commerce.
Synopsis of Rule of Law. In the absence of conflicting legislation by Congress, where a state law governing a matter of local concern comes into conflict with the Commerce Clause’s overriding requirement of a national “common market,” the Court is confronted with the task of bringing about an accommodation of the competing national and local interests.
Issue. Did the North Carolina statute violate the Commerce Clause by unreasonably burdening interstate commerce?
Although facially neutral, the statute had the effect of not only burdening interstate sales of Washington apples, but also discriminating against them.
For example, the statute raised the costs of doing business in North Carolina for Washington growers, while leaving the costs for North Carolina growers unaffected.
In addition, by prohibiting Washington growers from marketing their apples under their state’s more stringent grading system label, the statute has a “leveling effect” which operated to benefit local growers.
Moreover, non-discriminatory alternatives to the statute could have been used to accomplish the State’s local objectives. North Carolina could have permitted out-of-state growers to display their state labels only if they also used the USDA label.
Whether an association has standing to invoke the court's remedial powers on behalf of its members depends in substantial measure on the nature of the relief sought.View Full Point of Law