Pike v. Bruce Church, Inc.

Summary

The United States Supreme Court considered whether Arizona could prohibit a company from transporting uncrated cantaloupes to California for packing. The Court held that the state order imposed an unconstitutional burden on interstate commerce because it required an economically inefficient in-state packing operation to advance only a minimal state interest. The Court affirmed the permanent injunction against enforcement of the order.

Holdings

1. An order requiring Arizona-grown cantaloupes destined for California to be packed in Arizona affects and burdens interstate commerce, even though packing is an intrastate operation performed before shipment.
2. A statute that regulates evenhandedly to effectuate a legitimate local public interest and has only incidental effects on interstate commerce is valid unless the burden imposed on interstate commerce is clearly excessive in relation to the putative local benefits.
3. Arizona could not constitutionally require Bruce Church, Inc. to build and operate an unnecessary packing plant in Arizona merely to enhance the reputation of Arizona growers; the order imposed an unconstitutional burden on interstate commerce.

Questions Presented

1. Whether Arizona's order requiring the company to pack its cantaloupes within Arizona before shipping them to California affected and burdened interstate commerce.
2. Whether the order violated the Commerce Clause because its burden on interstate commerce was clearly excessive in relation to the asserted local benefits.
3. Whether Arizona could require the company to perform an economically inefficient packing operation within the State to enhance the reputation of Arizona growers.

Disposition

affirmed