Hunt v. Washington State Apple Advertising Commission

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Hunt v. Washington State Apple Advertising Commission

Supreme Court of the United States
Argued February 22, 1977
Decided June 20, 1977
Full case name Hunt, Governor of North Carolina, et al. v. Washington State Apple Advertising Commission
Citations 432 U.S. 333 (more)
Prior history Appeal from the United States District Court for the Eastern District of North Carolina
Subsequent history 408 F. Supp. 857, affirmed.
Holding
North Carolina violated the Commerce Clause by discriminating against out-of-state apple growers.
Court membership
Case opinions
Majority Burger, joined by unanimous court
Rehnquist took no part in the consideration or decision of the case.
Laws applied
U.S. Const. art. I § 8 cl. 3 (Commerce Clause)

Hunt v. Washington State Apple Advertising Commission, 432 U.S. 333 (1977)[1], was a case in which the Supreme Court of the United States unanimously struck down a North Carolina law requiring all importers of apples to label their containers with U.S. Dept. of Agriculture grade, and prohibiting the display of state grades. Washington State used apple standards superior to those used by the USDA. The Court found that North Carolina's law needlessly discriminated against Washington State apple producers while working to the advantage of local North Carolina apple growers.

Facts:

Challenge to North Carolina statute requiring crates of apples only be marked with the USDA grade/standard. Washington State applied higher standards than the USDA and claimed the law discriminated against the display of a superior product grade. Getting rid of the Washington State grade on crates to be shipped to North Carolina gave the crates a damaged appearance.

Issue:

Is the North Carolina state law protectionist/discriminatory in nature?

Holding:

Yes. The state law is invalid.

North Carolina's Argument:

North Carolina acknowledged the burden placed on Washington State, but said the burden was far outweighed by the local benefits and well within their police powers. The multiple grades, that were often similar in name, caused confusion and could lead to fraud within their states.

Reasoning:

The statute discriminated against Washington in a number of ways. First, it raised the cost of Washington State doing business in North Carolina while not doing the same for North Carolina apple production. North Carolina was not forced to alter their marketing practices as Washington State was. Second, it stripped Washington State of the competitive and economic advantages it had established through its nationally-accepted higher standards and expensive inspection system. Third, it lowered the superior Washington State grade to the lower USDA standard, leveling the playing field with North Carolina apples and giving North Carolina a decided advantage. North Carolina failed to show the unavailability of other nondiscriminatory alternatives. North Carolina claimed the law eliminated confusion and fraud, but permitted the marketing of crates of apples with no grade at all.

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