Thursday, November 14, 2013

City of Philadelphia v. New Jersey case brief

City of Philadelphia v. New Jersey case brief summary
437 U.S. 617 (1978)


CASE SYNOPSIS
Plaintiffs, landfill operators, challenged the decision of the Supreme Court of New Jersey, which affirmed the trial court's grant of summary judgment in favor of plaintiffs in their action against defendants, state and department, seeking declaration that N.J. Stat. Ann. § 13:1I-10 was unconstitutional because it discriminated against interstate commerce.

CASE FACTS
Plaintiffs, landfill operators, brought an action against defendants, state and department, arguing that N.J. Stat. Ann. 13:1I-10 was unconstitutional because it permitted four categories of waste to enter the state, and excluded plaintiffs. The trial court granted summary judgment in favor of plaintiffs, and the lower appellate court reversed, finding that the statute advanced vital health and environmental objectives with no economic discrimination against interstate commerce.

DISCUSSION
  • The court reversed, concluding that § 13:1I-10 was a protectionist measure and not a law directed to legitimate local concerns, with effects upon interstate commerce that are only incidental. 
  • The court concluded that no matter what defendant's ultimate purpose was, it could not be accomplished by discriminating against articles of commerce coming from outside the state unless there was some reason, apart from their origin, to treat them differently. 
  • The court concluded that § 13:1I-10 both on its face and in its plain effect violated the principle of nondiscrimination because on its face, it imposed on out-of-state commercial interests the full burden of conserving the state's remaining landfill space.
CONCLUSION
The court reversed the lower appellate court's reversal of the trial court's grant of summary judgment in favor of plaintiffs, landfill operators, after it held that a state statute banning waste from entering the state to be disposed of was unconstitutional. The court concluded that the state statute was a protectionist measure and not directed to legitimate concerns with only incidental effects on interstate commerce.


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