Saturday, December 7, 2013

Baldwin v. G.A.F. Seelig, Inc. case brief

Baldwin v. G.A.F. Seelig, Inc. case brief summary
294 U.S. 511 (1935)

Plaintiff milk dealer sought to restrain defendant state officials from prosecuting it for selling milk imported from Vermont without a license in New York. The United States District Court for the Southern District of New York found in favor of the milk dealer with respect to milk sold in the original package. The district court denied relief with respect to milk sold in bottles. Both the milk dealer and the state officials appealed.

The New York Milk Control Act (Act), 1933 N.Y. Laws 158, 1934 N.Y. Laws 126, established a system of minimum prices to be paid by milk dealers to producers in New York. The milk dealer bought its milk in Vermont at prices lower than the New York minimum and refused to agree to conform to the New York statute and regulations in the sale of the imported product. The milk dealer was thus unable to obtain a New York business license.


  • The Court held that the district court properly restrained the enforcement of the Act in its application to sales in the original packages but erred in refusing to grant an injunction with respect to milk in bottles. 
  • The form of the packages was immaterial. 
  • New York's attempt to regulate the price to be paid for milk acquired in Vermont had the same unconstitutional effect as a customs duty. 
  • The Court rejected the state officials' arguments that the purpose of the Act was not to protect its farmers from competition but to ensure an adequate supply of milk and to avoid tempting farmers to save the expense of sanitary precautions. 
  • Allowing a health exception would have destroyed the rule, and the relation was too indirect to obstruct interstate commerce.
The Court affirmed the decree, which enjoined the state officials with respect to milk sold in the original package, but reversed the denial of an injunction with respect to milk sold in bottles. The Court remanded for further proceedings.

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