Thursday, November 14, 2013

Bibb, Director, Dept. of Public Safety of Illinois v. Navajo Freight Lines, Inc. case brief

Bibb, Director, Dept. of Public Safety of Illinois v. Navajo Freight Lines, Inc. case brief summary
359 U.S. 520 (1959)


CASE SYNOPSIS
Appellant, director of the Department of Public Safety of Illinois, sought review of decision entered by the United States District Court for the Southern District of Illinois, which enjoined appellant's enforcement of the Illinois Splash Guard statute. The appeals court held that the statute violated the Commerce Clause because it interrupted interstate commerce conducted by appellees, interstate carriers.

CASE FACTS
Appellees, interstate carriers, challenged the constitutionality of the Illinois Splash Guard statute on the grounds that the statute conflicted with statutes of other states and that the statute burdened and obstructed interstate commerce because it made the conventional mudflap illegal in Illinois. The appeals court enjoined appellant director of the Department of Public Safety of Illinois from enforcing the statute on the ground that it violated the Commerce Clause.

DISCUSSION
  • The Supreme Court affirmed that decision on certiorari. 
  • The Court held that the local safety measure balanced against the burden on commerce violated the Commerce Clause because the mudflap design was so out of line with the requirements of almost all other states that appellees assumed a great burden to comply with the statute; the inconsistency of mudflap designs delayed interstate commerce and inconvenienced appellees who were forced to seek ways to comply with the statute.

CONCLUSION
The Court affirmed the decision of the appeals court and held that the Illinois Splash Guard statute violated the Commerce Clause because it placed an unconstitutional burden on appellees, interstate carriers, and had a deleterious effect on interstate commerce.

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