Thursday, November 14, 2013

Pike v. Bruce Church, Inc. case brief

Pike v. Bruce Church, Inc. case brief summary
397 U.S. 137 (1970)

CASE SYNOPSIS
Appellee farming company sought an appeal of an order issued by appellant official, who was charged with enforcing the Arizona Fruit and Vegetable Standardization Act, Ariz. Rev. Stat. Ann. tit. 3, ch. 3, Article 4. The official appealed a decision from the United States District Court for the District of Arizona granting a permanent injunction upon the ground that the order constituted an unlawful burden upon interstate commerce.

CASE FACTS
A provision of the Arizona Fruit and Vegetable Standardization Act, Ariz. Rev. Stat. Ann. § 3-503 (Supp. 1969), prohibited interstate shipment of cantaloupes not packed in regular compact arrangements in closed standard containers. Invoking his authority under that provision, appellant issued an order that prohibited appellee from transporting uncrated cantaloupes from its ranch in Arizona to California for packing and processing. Appellee then brought an action in federal court to enjoin the order as unconstitutional, which issued a permanent injunction upon the ground that the challenged order constituted an unlawful burden upon interstate commerce.


DISCUSSION

  • On appeal, the United States Supreme Court reviewed the record and recognized the State's interest to promote and preserve the reputation of Arizona growers by prohibiting deceptive packaging. 
  • However, the Court refused to accord that interest much weight when balancing it against the burden on interstate commerce. 
  • Despite the statutory provision's unchallenged existence and the legitimacy of the State's interest, the Court determined that the interest was not important enough to justify the burden on interstate commerce.

CONCLUSION
The Court affirmed the injunction issued by the district court and held that appellant's order was unconstitutional under the Commerce Clause, concluding that the State's interest in promoting and preserving the reputation of Arizona growers by prohibiting deceptive packaging was not important enough to justify the burden on interstate commerce.

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