Tuesday, November 5, 2013

Exxon Corp. v. Governor of Maryland case brief

Exxon Corp. v. Governor of Maryland case brief summary
437 U.S. 117 (1978)


CASE SYNOPSIS
Petitioners appealed from the Court of Appeals of Maryland, which rejected their allegations that certain provisions of Md. Ann. Code art. 56, § 157E, violated the Due Process andCommerce Clauses and were in conflict with the Robinson-Patman Act, 15 U.S.C.S. § 13.

CASE FACTS
Petitioners, producers of petroleum products, contended that certain provisions of Md. Ann. Code art. 56, § 157E, violated the Due Process and Commerce Clauses, and directly conflicted with the Robinson-Patman Act, 15 U.S.C.S. § 13. The provisions in question did not allow petitioners to operate any retail service stations in the state, and required petitioners to extend voluntary allowances to all service stations they supplied.


DISCUSSION

  • The Court rejected petitioners' due process claim, because the statute was reasonably related to the state's purpose in controlling the retail gas market. 
  • The statute did not violate the Commerce Clause, because it did not prohibit the flow of interstate goods or distinguish between in-state and out-of-state companies. 
  • The provisions were not invalid merely because they could have an anticompetitive effect undermining the Robinson-Patman Act. 
  • The Court held that the state's power to make economic regulations would be stifled if an adverse effect on competition was enough to invalidate a statute.

CONCLUSION
The Court affirmed the decision rejecting petitioner's allegations, where state statute did not burden or discriminate against interstate commerce and was reasonably related to the state's purpose in controlling the retail market for gasoline. The anticompetitive effect of the statute was not enough to render the statute invalid.

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