In 1972, the North Carolina Board of Agriculture adopted a regulation that required all apples shipped into the state in closed containers to display the USDA grade or nothing at all. Washington State growers(whose standards are higher than the USDA) challenged the regulation as an unreasonable burden to interstate commerce. North Carolina stated it was a valid exercise of its police powers to create "uniformity" to protect its citizenry from "fraud and deception."
Did the North Carolina regulation violate the Commerce Clause by placing an unreasonable burden on interstate commerce?
The Court voted unanimously that the North Carolina regulation was an unconstitutional exercise of the state's power over interstate commerce. Although the regulation was facially neutral, it had a discriminatory impact on the Washington growers while shielding the local growers from the same burden. The regulation removed the competitive advantage gained by the Washington apples from stricter inspection standards. The regulation produced a leveling effect that works to the local advantage by "downgrading" apples from other states unjustly. Therefore, the regulation places an unreasonable burden on interstate commerce.
Decisions
Decision: 8 votes for Wash. State Apple Ad. Comm., 0 vote(s) against Legal provision: Article 1, Section 8, Paragraph 3: Interstate Commerce Clause
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Full Opinion by Justice Warren E. Burger
