Summary of Minnesota v. Clover Leaf Creamery Co.
449 U. S. 456 (1981)
Facts: Minnesota Legislature enacted a statute banning the sale of milk in nonreturnable, nonrefillable containers, but permitting such sale in other nonreturnable, nonrefillable containers, such as paperboard, milk cartons. Pl/Resp. are a dairy that owns equipment for producing plastic nonreturnable containers.
Issue: Whether the Act/statute violates the Equal Protection Clause and the Commerce Clause?
Procedure: Dist. Ct. found for Respondents, “actual basis," for the Act was to promote economic interests of certain groups. S. Ct. Minn. Affirmed violated Equal and Due Process w/o addressing the Commerce question. Reversed.
Rule: 14th – No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the U.S.; without due process of law, nor deny equal protection of the laws. States are prohibited from enacting unreasonable burdens on interstate commerce.
Ct. Rationale: The Act sought to promote resource conservation, easing solid waste disposal problems, and conserving energy – legitimate state purposes. The Act regulates evenhandedly by prohibiting all milk retailers from selling their products in the proscribed containers, irrespective of whether intra or interstate businesses. Most dairies package their products in more than one type of package, the additional requirement is only slight. The degree on out of state production of plastic resin, versus in state pulp producers is of a low degree and not clearly excessive.
PL A : The Act serves a discriminatory purpose. The Act’s actual basis was to promote the economic interests of certain segments of the local dairy and pulpwood industries at the expense of other segment.
Def A: The purpose of the Act was to promote resource conservation, easing solid waste problems, and conserving energy. Legitimate state purposes.
Putative – Reputed or supposed. Commonly esteemed.
Incidental burden test – If the incidental burden imposed on interstate commerce is clearly excessive in relation to the putative local benefits.
Rational basis test – The purpose of an Act must be legitimate state purposes. The legislative classification must be rationally related to the achievement of the statutory purpose.