Raymond Kassel v. Consolidated Freightways Corp. of Delaware case brief

Raymond Kassel v. Consolidated Freightways Corp. of Delaware case brief summary

450 U.S. 662 (1981)

CASE SYNOPSIS

Appellant interstate trucking firm challenged statutory restrictions imposed by appellee state, which barred 65 foot long "double" tractor trailers from Iowa's interstate highways. The district court held that the statutory scheme found in Iowa Code § 321.457 (1979) unconstitutionally burdened interstate commerce; the United States Court of Appeals for the Eighth Circuit affirmed. Appellees, state and state officials, sought further review.

CASE FACTS
The state, claiming that double trailers were less safe than single tractor-trailers, enacted a law that banned the use of 65-foot long double trailers from its interstate highways; exemptions were granted to border cities, farm vehicles, and trucks manufactured and mobile homes moved within the state. Iowa Code § 321.457(3)-(6) (1979). Because of the statutory ban, the trucking firm was required either to divert its trucks from Iowa or detach trailers to shuttle them separately through the state. The lower courts declared the statute unconstitutional under the Commerce Clause.


DISCUSSION

• On appeal, the court affirmed. 
• It held that the state failed to present any persuasive evidence that double trailers were in fact less safe than single ones and found that the statute deferred to local interests while substantially burdening the flow of interstate goods. 
• It noted that although normally state highway safety regulations were given deference by the courts and were presumptively valid, that presumption was overcome where the negative impact on interstate commerce was substantial and the alleged safety reasons for enacting the statute were unproven.

CONCLUSION
The court affirmed the appellate court's determination that Iowa's disputed double trailer ban was unconstitutional under the Commerce Clause.

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