City of Philadelphia v. New Jersey

Summary

The United States Supreme Court held that New Jersey's prohibition on importing most out-of-state solid waste violated the dormant Commerce Clause. Although environmental protection and waste-disposal concerns were legitimate objectives, the statute impermissibly discriminated against interstate commerce by allowing in-state waste while excluding waste based on its out-of-state origin. The Court also concluded that the state law was not preempted by federal solid-waste legislation and reversed the judgment of the New Jersey Supreme Court.

Holdings

1. New Jersey's law was not preempted by federal legislation governing solid-waste management and transportation.
2. All objects of interstate trade, including out-of-state waste, are within the scope of Commerce Clause protection; waste is not excluded from constitutional scrutiny merely because it may be valueless or harmful.
3. New Jersey's law violated the Commerce Clause because it facially discriminated against interstate commerce by prohibiting out-of-state waste while permitting comparable in-state waste to enter the State's landfills.

Questions Presented

1. Whether federal solid-waste legislation preempted New Jersey's restrictions on the importation and disposal of out-of-state waste.
2. Whether New Jersey's facially discriminatory ban on most out-of-state solid and liquid waste violated the Commerce Clause.
3. Whether interstate movement of waste constitutes commerce entitled to Commerce Clause protection.

Disposition

reversed