Wednesday, November 6, 2013

Maine v. Taylor & United States case brief

Maine v. Taylor & United States case brief summary
477 U.S. 131 (1986)

The State sought review of a decision of the United States Court of Appeals for the First Circuit, which reversed defendant's conviction under 16 U.S.C.S. § 3372(a)(2)(A) on the ground that the underlying state statute, Me. Rev. Stat. Ann. tit. 12, § 7613, impermissibly restricted interstate trade.

Defendant operated a bait business. Despite the state statute, Me. Rev. Stat. Ann. title 12, § 7613, prohibiting the importation of live baitfish, defendant arranged to have live bait delivered to him from outside the state. The shipment was intercepted and defendant was indicted under § 3(a)(2)(A) of the Lacey Act Amendments, 16 U.S.C.S. § 3372(a)(2)(A). Defendant's subsequent conviction was overturned on the ground that the underlying state statute impermissibly restricted interstate trade.


  • Upon its determination that it had jurisdiction, the Supreme Court held that defendant's conviction was not clearly erroneous since evidence showed that no alternative means existed to promote the local purpose as well without discriminating against interstate commerce. 
  • The abstract possibility of developing acceptable testing procedures did not make those procedures an available nondiscriminatory alternative. 
  • As such, the state statute permissibly served a legitimate local purpose and defendant's conviction was proper.

The Court reversed, holding that the state retained broad regulatory authority to protect the health and safety of its citizens and the integrity of its natural resources. The evidence amply supported the district court's findings that the statute served a legitimate local purpose that could not adequately be served by available nondiscriminatory alternatives.

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