Minnesota v. Clover Leaf Creamery Co. (1981)
Facts/Issue/Holding: MN law banned milk sales in plastic non-returnable bottles, but permitted non-returnable paperboard containers. Court upholds law as constitutional.
· The Court assumes that objectives articulated by legislature are the actual objectives of statute (exceptional circumstances may force Court to alter this assumption).
· Proof that legislature was MISTAKEN in creating classifications to serve a state goal does NOT show that the classifications are not rationally related to the furtherance of a state goal.
o If issue was “at least debatable” to legislature creating the statute, evidence showing classification is not rational will not prevail.
o States do not have to convince Court of correctness of legislative judgments. Even if shown that statute does not fulfill the objectives intended to fulfill, still cannot be used as proof of statute’s irrationality for rational basis review.
Strict Scrutiny (“SS”)
TEST: Law must be “narrowly tailored to further a compelling state interest”
· Use heightened means of scrutiny to “smoke out” underlying “irrational” prejudice
· If over- or under-inclusive, law gets struck down. Virtually impossible to pass strict scrutiny due to the narrow requirement, law rarely so well tailored
JR’s two modes of analyzing state actions under SS:
1) Justificatory. Balance state interest with harm to the individuals involved. In the case of racial profiling, provide evidence on how well it stops crime. Cost/benefit analysis, balancing of interests.
2) Purposivist (very different). What were the reasons behind the state legislation or objectives behind the action? Some state interests are illegitimate to pursue no matter what the cost/benefit.