Citation. 450 U.S. 662, 101 S. Ct. 1309, 67 L. Ed. 2d 580, 1981 U.S. 17.
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Brief Fact Summary.
Iowa prohibits the use of 65 foot doubles (a certain type of truck) within its borders, but makes certain exceptions for the same trucks used for the benefit of Iowa residents.
Synopsis of Rule of Law.
State regulations designed to promote public health or safety, but further such purposes only marginally and interfere with commerce substantially may be invalid under the Commerce Clause.
Iowa, unlike all other States nearby it, prohibits the use of 65-foot doubles within its borders. Notwithstanding this restriction, Iowa allows its border cities to adopt the truck length limitations of the states adjoining them. Iowa also allows Iowa truck manufacturers to obtain a permit to ship trucks out of the state as long as 70 feet long. Mobile homes are also eligible for exemptions, as long as they are being used to benefit Iowa residents. Dissatisfied, the Plaintiff, Consolidated Freightways Corp. (Plaintiff), filed suit in the District Court arguing the Iowa’s scheme unconstitutionally burdened interstate commerce. Iowa claimed that it enacted its scheme lawfully for the purpose of promoting local safety.
Was Iowa’s statute scheme an unreasonable safety measure enacted pursuant to its police powers?
Yes. The judgment of the Court of Appeals is affirmed.
Iowa failed to produce any persuasive evidence that 65-foot doubles are less safe than 55-foort singles. Plus, Iowa’s law substantially burdens interstate commerce insofar as it uses regulations out of step with all of its neighboring State’s regulations. Moreover, Iowa discriminates against out-of-state interests by providing Iowan’s exemptions that are not extended to out-of-state interests.
Although the Supreme Court of the United States usually (Supreme Court) defers to the judgment of the State legislatures as to the justification of its laws concerning local concerns, less deference is due them in cases such as these: where the State’s safety justifications appear illusory; and where local regulation places a disproportionate burden of its statutory scheme on out-of-state interests.
Concurrence. Justice William Brennan (J. Brennan) states that even if the burdens and benefits are related to safety, protectionist legislation is unconstitutional under the Commerce Clause.
Justice William Rehnquist (J. Rehnquist) states that where a state enacts a statute for the purpose of promoting safety, the Court should not directly compare safety benefits to commerce burdens and strike the law if former weighs heavier. Instead the Court should engage in a “sensitive consideration” to determine if an asserted safety justification is merely a pretext for discriminating against interstate commerce.
This case involves an apparently facially neutral statute with out-of-state effects that may exceed in-state benefits. As such, much emphasis is placed on the cost/benefit factors resulting from the regulation. Whether it is appropriate for the courts to fix the lawfulness of a statute on this type of retrospective review is debat