GRANHOLM v. HEALD

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Case Basics
Docket No. 
03-1116
Petitioner 
Jennifer M. Granholm, Governor of Michigan, et al.
Respondent 
Edward D. Kelly, Chairman, New York Division of Alcoholic Beverage Control, State Liquor Authority, et al.
Consolidation 
Michigan Beer & Wine Wholesalers Association v. Eleanor Heald et al., No. 03-1120
Juanita Swedenburg, et al. v. Edward D. Kelly, Chairman, New York Division of Alcoholic Beverage Control, State Liquor Authority, et al., No. 03-1274
Advocates
(argued the cause for Petitioners in 03-1116 & 03-1120)
(argued the cause for Petitioners in 03-1274)
(argued the cause for Respondents in 03-1116 & 03-1120)
(argued the cause for Respondents in 03-1274)
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Facts of the Case 

Michigan and New York laws allowed in-state wineries to directly ship alcohol to consumers but restricted the ability of out-of-state wineries to do so. In separate cases groups sued the states and argued the laws violated the U.S. Constitution's "dormant" commerce clause. The dormant commerce clause prohibited states from passing laws affecting interstate commerce, particularly laws favoring in-state business over out-of-state business. The states argued the laws were valid exercises of state power under the 21st Amendment, which ended federal Prohibition and allowed states to regulate alcohol importation. A federal district court ruled for Michigan. The Sixth Circuit Court of Appeals reversed and ruled the Michigan law violated the dormant commerce clause and did not advance the core concerns of the 21st Amendment (such as temperance). A separate federal district court ruled against New York. The Second Circuit Court of Appeals reversed and ruled the 21st Amendment allowed New York's law.

Question 

Does a state law that allows in-state wineries to directly ship alcohol to consumers, but restricts the ability of out-of-state wineries to do so, violate the dormant commerce clause in light of the 21st Amendment?

Conclusion 
Decision: 5 votes for Heald, 4 vote(s) against
Legal provision: Article 1, Section 8, Paragraph 3: Interstate Commerce Clause

Yes. In a 5-4 opinion delivered by Justice Anthony Kennedy, the Court held that both states' laws violated the commerce clause by favoring in-state wineries at the expense of out-of-state wineries and did so without the authorization of the 21st Amendment. State authority to engage in such economic discrimination was not the purpose the 21st Amendment. Moreover, in modern cases, that amendment did not save state laws violating other provisions of the Constitution.

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GRANHOLM v. HEALD. The Oyez Project at IIT Chicago-Kent College of Law. 23 October 2014. <http://www.oyez.org/cases/2000-2009/2004/2004_03_1116>.
GRANHOLM v. HEALD, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2004/2004_03_1116 (last visited October 23, 2014).
"GRANHOLM v. HEALD," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 23, 2014, http://www.oyez.org/cases/2000-2009/2004/2004_03_1116.