Friday, November 15, 2013

United Haulers Assn., Inc. v. Oneida-Herkimer Solid Waste Management Authority case brief

United Haulers Assn., Inc. v. Oneida-Herkimer Solid Waste Management Authority case brief summary
127 S. Ct. 1786 (2007)

CASE SYNOPSIS
Petitioners, a trade association and waste haulers, sued respondents, Oneida County and Herkimer County, New York, and the Oneida-Herkimer Solid Waste Management Authority, pursuant to 42 U.S.C.S. § 1983, challenging the Counties' flow control ordinances. The district court ruled in favor of respondents, and the United States Court of Appeals for the Second Circuit ultimately affirmed. The Supreme Court granted certiorari in both cases.

CASE FACTS
The Counties and the Authority, which was a public benefit corporation, had entered into an agreement that called for the Authority to manage solid waste. The Authority, which provided recycling and other services at its facilities, collected tipping fees from private waste collectors that significantly exceeded fees charged at waste processing facilities in the open market. The Counties enacted flow control ordinances requiring all solid waste generated within the Counties to be delivered to the Authority's processing facilities.

DISCUSSION
  • The Court found that the flow control ordinances did not violate the Commerce Clause, U.S. Constitutional Article I, § 8, cl. 3. 
  • Although an ordinance that favored a particular private business would have violated the dormant Commerce Clause, the Counties' ordinances did not discriminate against interstate commerce because they benefitted a clearly public facility while treating all private companies exactly the same. 
  • It was not the office of the Commerce Clause to determine whether government or the private sector should provide waste management services or to override state policy that favored displacing competition with regulation in the waste management area.

CONCLUSION

The Second Circuit's judgments were affirmed.

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