Hunt, Governor of the State of North Carolina v. Washington State
Apple Advertising Commn. Case brief summary
432 U.S. 333 (1977)
CASE SYNOPSIS
Appellee state apple advertising
commission brought an action challenging the constitutionality under
the Commerce Clause of appellant state's statute
prohibiting closed containers of apples shipped into the state from
bearing any grade other than the applicable United States grade. The
United States District Court for the Eastern District of North
Carolina invalidated the statute and granted injunctive relief.
Appellant sought review.
CASE FACTS
Appellant state enacted N.C. Gen. Stat. § 106-189.1, prohibiting closed containers of apples shipped into the state from displaying state grades or classifications. Appellee sued, asserting that the statute violated the Commerce Clause and seeking injunctive relief from its enforcement. The district court granted the requested relief.
DISCUSSION
On review, the Court affirmed. It held that appellee had standing to sue because it performed the functions of a traditional trade association representing the state apple industry. The Court also held that the jurisdictional amount in controversy of 28 U.S.C.S. § 1331 was met, because appellee's substantial volume of sales and the continuing nature of the statute's impact on sales precluded a finding to a legal certainty that its losses and expenses would not total the requisite $ 10,000. The Court finally held that the statute both burdened and discriminated against the interstate sale of apples and that appellant did not meet the burden of demonstrating substantial local benefits flowing from the statute and the unavailability of nondiscriminatory alternatives adequate to preserve local interests.
CONCLUSION
The Court affirmed. It held that appellee had standing to challenge the statute, that the jurisdictional amount in controversy requirement was met, and that the challenged statute burdened and discriminated against interstate sales of apples from appellee; appellant failed to sustain its burden of showing substantial local benefits flowing from the statute and the unavailability of nondiscriminatory alternatives.
432 U.S. 333 (1977)
CASE SYNOPSIS
CASE FACTS
Appellant state enacted N.C. Gen. Stat. § 106-189.1, prohibiting closed containers of apples shipped into the state from displaying state grades or classifications. Appellee sued, asserting that the statute violated the Commerce Clause and seeking injunctive relief from its enforcement. The district court granted the requested relief.
DISCUSSION
On review, the Court affirmed. It held that appellee had standing to sue because it performed the functions of a traditional trade association representing the state apple industry. The Court also held that the jurisdictional amount in controversy of 28 U.S.C.S. § 1331 was met, because appellee's substantial volume of sales and the continuing nature of the statute's impact on sales precluded a finding to a legal certainty that its losses and expenses would not total the requisite $ 10,000. The Court finally held that the statute both burdened and discriminated against the interstate sale of apples and that appellant did not meet the burden of demonstrating substantial local benefits flowing from the statute and the unavailability of nondiscriminatory alternatives adequate to preserve local interests.
CONCLUSION
The Court affirmed. It held that appellee had standing to challenge the statute, that the jurisdictional amount in controversy requirement was met, and that the challenged statute burdened and discriminated against interstate sales of apples from appellee; appellant failed to sustain its burden of showing substantial local benefits flowing from the statute and the unavailability of nondiscriminatory alternatives.
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