Florida Lime & Avocado Growers, Inc. v. Paul, Director, Dept. of Agriculture of California case brief

Florida Lime & Avocado Growers, Inc. v. Paul, Director, Dept. of Agriculture of California case brief summary
373 U.S. 132 (1963)

CASE SYNOPSIS

Appellant avocado growers and handlers challenged a judgment from the United States District Court for the Northern District of California holding that Cal. Agric. Code § 792 was constitutional and enforceable by appellee state government, despite the existence of the Agricultural Adjustment Act, 7 U.S.C.S. §§ 601 et seq.

CASE FACTS
Appellant avocado growers and handlers challenged the constitutionality of Cal. Agric. Code § 792 insofar as it was applied by appellee government to exclude certain out-of-state avocados from California. The district court held that § 792 was constitutional.


DISCUSSION

• The United States Supreme Court affirmed the judgment regarding appellants' challenges under U.S. Constitutional art. VI (Supremacy Clause) and U.S. Constitutional Amendment XIV (Equal Protection Clause) and reversed the judgment as to the U.S. Constitutional art. I, §8 (Commerce Clause) challenge. 
• The statute did not violate the Supremacy Clause because compliance with § 792 and the Agricultural Adjustment Act (the Act), 7 U.S.C.S. § 608c(3) and (4), was not impossible, the subject matter of the statute was not subject to exclusive federal regulation, and Congress did not intend the Act to displace state regulations. 
• Section 792 did not violate the Equal Protection Clause because it was not arbitrary or devoid of rational relationship to a legitimate regulatory interest. 
• The record was insufficient for the Court to determine whether § 792 violated the Commerce Clause; thus, that portion of the judgment was reversed and remanded.

CONCLUSION

The judgment that the state statute did not violate the Supremacy and Equal Protection clauses was affirmed. The judgment that the statute did not violate the Commerce Clausewas reversed and remanded for a new trial insofar as the judgment sustains § 792 against appellants' challenge to the statute grounded on the Commerce Clause.