Kassel v. Consolidated Freightways Corporation

Citation. 450 U.S. 662, 101 S.Ct. 1309, 67 L.Ed.2d 580 (1981)

Brief Fact Summary.

An Iowa statute barred all 65-foot trailers from its roadways except for ones from cities that bordered Iowa.  The statute, however, allowed trailers less than 55 feet.  Iowa justified the statute by arguing that smaller trailers are safer and would cause less wear and tear on the roadways.  A trucking company that incurred significant added costs from the statute sued, alleging it violated the Commerce Clause.

Synopsis of Rule of Law.

State regulations that promote “public health or safety” are presumed valid.  However, if a regulation significantly impairs interstate commerce and the justifications for the regulation are illusory, the regulation violates the Commerce Clause.

Facts.

An Iowa statute barred all tractor trailers over 55 feet in length from its roadways except for ones from cities that bordered Iowa.  Iowa justified the statute by arguing that smaller tractor trailers were safer and would cause less wear and tear on the roadways.  More specifically, the State argued that smaller trailers take less time to be passed and to clear intersections, they can back up easier, and they are less likely to “jackknife.” However, every other State in the region allowed 65-foot trucks.

Consolidated Freightways, a trucking company based in Delaware, regularly employed 65-foot trucks and wanted to drive them through Iowa.  Because of the Iowa statute, however, Consolidated Freightways had to either use smaller trucks or divert around Iowa, costing the company over $2 million per year in added costs.  Consolidated Freightways sued, alleging that the Iowa statute unconstitutionally burdened interstate commerce.

Issue.

Whether the Iowa statute banning 65-foot trailers from its roadways posed an unconstitutional burden on interstate commerce.

Held.

JUSTICE POWELL holding:  Yes.  The State presented no evidence to prove that 65-foot trailers were more dangerous than smaller ones, and the regulation cost out-of-state trucking companies millions of dollars.

Dissent.

Justice Rehnquist

Justice Rehnquist believed that both the plurality and the concurrence overstepped the Court’s bounds.  When safety regulations are at issue, the Court must only consider whether the safety justification was mere pretext.  If the safety justification was not pretextual, then the regulation will be presumed to be valid.  To overcome this presumption, the party seeking to invalidate the regulation would have to show that the “benefits from the regulation are demonstrably trivial while the burden on commerce is great.”  Here, the trucking company produced no evidence to undermine the State’s conclusion that truck length was related to safety, so the regulation should have been upheld.  The plurality’s vague policy balancing did not give guidance to States or businesses on what States can regulate under the Commerce Clause.

Addressing Justice Brennan’s concurrence, Rehnquist argued that Court has consistently rejected using the legislative history to determine a statute’s validity.  He reasoned that individual legislators will have different opinions, so it is not possible to determine the legislature’s “actual purpose.”

Concurrence.

Justice Brennan

Justice Brennan would have invalidated the statute not because truck lengths had a negligible effect on vehicle safety, but because the statute was “protectionist.”  In Brennan’s view, “the only relevant evidence concerns whether the lawmakers could rationally have believed that the challenged regulation would foster [its intended] purposes.”  Here, the legislative history showed that the statute was not intended to increase safety, but to benefit Iowa at the expense of other States.  This “protectionist” rationale is barred by the Commerce Clause.

Discussion.

We have long held a state tax law is not arbitrary although it discriminates in favor of a certain class if the discrimination is founded upon a reasonable distinction that does not to conflict with the Constitution, including the Equal Protection Clause. This principle applies here as well. The statute is well within those limits. Judgement affirmed.