Bibb v. Navajo Freight Lines, Inc.: Difference between revisions
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The state of [[Illinois]] enacted a [[statute]] requiring curved [[fender (vehicle)|mud guard]]s, instead of [[mudflap]]s. Although there was no federal regulation requiring mudflaps or mudguards, [[Arkansas]] required mudflaps and prohibited mudguards, and 45 states permitted either.<ref>{{cite book|last=Douglas|first=William|title=Bibb v. Navajo Freight Lines, Inc.|location=359 U.S. 520, 1959|url=http://www.law.cornell.edu/supct/html/historics/USSC_CR_0359_0520_ZO.html}}</ref> The legislature asserted that rear mudguards would be more useful in preventing stones and other debris from the back of trucks, this preventing more accidents than other types of mudflaps. The plaintiffs were trucking companies who would have to use one form of equipment in one state, but other equipment in other states. The named plaintiff was Navajo Freight Lines, Inc., of [[New Mexico]]. |
The state of [[Illinois]] enacted a [[statute]] requiring curved [[fender (vehicle)|mud guard]]s, instead of [[mudflap]]s. Although there was no federal regulation requiring mudflaps or mudguards, [[Arkansas]] required mudflaps and prohibited mudguards, and 45 states permitted either.<ref>{{cite book|last=Douglas|first=William|title=Bibb v. Navajo Freight Lines, Inc.|location=359 U.S. 520, 1959|url=http://www.law.cornell.edu/supct/html/historics/USSC_CR_0359_0520_ZO.html}}</ref> The legislature asserted that rear mudguards would be more useful in preventing stones and other debris from the back of trucks, this preventing more accidents than other types of mudflaps. The plaintiffs were trucking companies who would have to use one form of equipment in one state, but other equipment in other states. The named plaintiff was Navajo Freight Lines, Inc., of [[New Mexico]]. |
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The only issue was whether in the absence of federal regulation, the Commerce Clause allows one State to prescribe standards for interstate carriers that would conflict with the standards of another State, so-called "dormant commerce clause" legislation. |
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The only issue was whether the Illinois statute was constitutional as written. |
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== Opinion of the Court == |
== Opinion of the Court == |
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Revision as of 15:38, 31 January 2012
| Bibb v. Navajo Freight Lines, Inc. | |
|---|---|
 | |
| Argued March 30–31, 1959 Decided May 25, 1959 | |
| Full case name | Bibb, Director, Department of Public Safety of Illinois v. Navajo Freight Lines, Inc., et al. |
| Citations | 359 U.S. 520 (more) 79 S. Ct. 962; 3 L. Ed. 2d 1003; 1959 U.S. LEXIS 1777 |
| Case history | |
| Prior | Appeal from the United States District Court for the Southern District of Illinois |
| Holding | |
| The Illinois law requiring trucks to have mudguards was unconstitutional under the Commerce clause. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Douglas, joined by Warren, Black, Frankfurter, Clark, Brennan, Whittaker |
| Concurrence | Harlan, joined by Stewart |
| Laws applied | |
| Commerce clause Article 1, Section 8, Paragraph 3: Interstate Commerce Clause | |
Bibb v. Navajo Freight Lines, Inc., 359 U.S. 520 (1959), is a United States Supreme Court case in which the Court held that the Illinois law requiring trucks to have mudguards was unconstitutional under the Commerce clause.
Background
The state of Illinois enacted a statute requiring curved mud guards, instead of mudflaps. Although there was no federal regulation requiring mudflaps or mudguards, Arkansas required mudflaps and prohibited mudguards, and 45 states permitted either.[1] The legislature asserted that rear mudguards would be more useful in preventing stones and other debris from the back of trucks, this preventing more accidents than other types of mudflaps. The plaintiffs were trucking companies who would have to use one form of equipment in one state, but other equipment in other states. The named plaintiff was Navajo Freight Lines, Inc., of New Mexico.
The only issue was whether in the absence of federal regulation, the Commerce Clause allows one State to prescribe standards for interstate carriers that would conflict with the standards of another State, so-called "dormant commerce clause" legislation.
Opinion of the Court
The Supreme Court held that the Illinois law was unconstitutional under the Commerce clause, technically the Dormant Commerce Clause.
In Bibb v. Navajo Freight Lines, 359 U.S. 520, 524 (1959), the Supreme Court stated:
These safety measures carry a strong presumption of validity when challenged in court. If there are alternative ways of solving a problem, we do not sit to determine which of them is best suited to achieve a valid state objective. Policy decisions are for the state legislature, absent federal entry into the field. Unless we can conclude on the whole record that "the total effect of the law as a safety measure in reducing accidents and casualties is so slight or problematical as not to outweigh the national interest in keeping interstate commerce free from interferences which seriously impede it we must uphold the statute."
— Bibb v. Navajo Freight Lines, Inc.
The court was unanimous, but Justice Harlan filed a concurrence, which was joined by Justice Stewart.
Subsequent developments
It is considered one of the leading precedents on the law of Interstate commerce.[citation needed]
External links
- Bibb v. Navajo Freight Lines, Inc. on Oyez.com
- Bibb v. Navajo Freight Lines, Inc. on Law.jRank.org
- Bibb v. Navajo Freight Lines, Inc. on Cornell Law School website
- Bibb v. Navajo Freight Lines, Inc. on FindLaw.com website
References
- ^ Douglas, William. Bibb v. Navajo Freight Lines, Inc. 359 U.S. 520, 1959.
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