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In 1933, the state of California enacted the California Prorate Act. The Act restricted competition among producers in order to stabilize prices. Brown, a raisin producer, attempted to enjoin enforcement of the Act on the ground that he was sustaining irreparable economic injuries under the program because of its regulations on contracts.
Did the California Act violate the Commerce Clause?
In a unanimous decision, the Court held that the program created by the California Prorate Act of 1933 was a regulation of state industry of local concern that did not impair national control over commerce. The Court noted that states had authority to regulate local matters so long as they did not materially obstruct commerce. The Court also found that the effects of the California Act paralleled the desired effects of congressional legislation. Since both California and the Congress were attempting to stabilize agricultural prices, no conflict between local and national interests was present.