State of Minnesota v. Clover Leaf Creamery Co. case brief

State of Minnesota v. Clover Leaf Creamery Co. case brief summary

449 U.S. 456 (1981)

CASE SYNOPSIS

Petitioner state challenged the order of the Supreme Court of Minnesota, which enjoined the enforcement of Minn. Stat. § 116F.21 (1978), which banned the retail sale of milk in plastic nonreturnable, nonrefillable containers, but permitted the sale of milk in other nonreturnable, nonrefillable containers. Respondent dairy contended that the statute violated the Equal Protection and Commerce Clauses.

DISCUSSION

• The Court reversed the order that enjoined the enforcement of Minn. Stat. § 116F.21 (1978), which banned the retail sale of milk in plastic nonreturnable, nonrefillable containers, but permitted milk sales other containers. 
• The controversy centered on the narrow issue of whether the legislative classification between plastic and nonplastic, nonreturnable milk containers was rationally related to achievement of conservation. 
• Because the question was at least debatable, the state supreme court erred in substituting its judgment for the legislature's. 
• The Court sustained § 116F.21 under the Equal Protection Clause, concluding that it was rationally related to the State's objectives. 
• From there, it followed that § 116F.21did not violate the Fourteenth Amendment's Due Process Clause. As to the Commerce Clause, the Court found that § 116F.21 did not discriminate between interstate and intrastate commerce. 
• The controlling question was whether the incidental burden imposed on interstate commerce by § 116F.21 was clearly excessive in relation to the local benefits.
• The statute's burden on interstate commerce was relatively minor, and there was a substantial State interest involved.

CONCLUSION

The Court reversed the state supreme court's order and sustained the state statute that banned the sale of nonreturnable, nonrefillable plastic milk containers.