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An inquiry regarding the validity of state statutes affecting interstate commerce necessarily involves a sensitive consideration of the weight and nature of the state regulatory concern in light of the extent of the burden imposed on the course of interstate commerce. The general rule is as follows: Where the statute regulates evenhandedly to effectuate a legitimate local public interest, and its effects on interstate commerce are only incidental, it will be upheld unless the burden imposed on such commerce is clearly excessive in relation to the putative local benefits. If a legitimate local purpose is found, then the question becomes one of degree. And the extent of the burden that will be tolerated will of course depend on the nature of the local interest involved, and on whether it could be promoted as well with a lesser impact on interstate activities.
Wisconsin statutes, as a general rule, do not allow trucks longer than 55 feet or pulling more than one other vehicle to be operated on highways within that State without a permit. Implementing regulations set forth the conditions under which "trailer train" and other classes of permits will be issued, and contain a great number of exceptions to the general rule. Appellant motor carriers were denied permits to operate 65-foot double-trailer units on certain interstate highways in Wisconsin on the ground that their proposed operations were not within the narrow scope of the regulations specifying when "trailer train" permits will be issued. Appellants then filed suit in Federal District Court seeking declaratory and injunctive relief on the ground that the regulations barring their operation of 65-foot doubles burdened and discriminated against interstate commerce in violation of the Commerce Clause. At the trial appellants presented extensive, uncontradicted evidence that the 65-foot doubles are as safe as, if not safer than, 55-foot signals when operated on limited-access, four-lane divided highways, and also presented uncontradicted evidence that their operations are disrupted, their costs raised, and their service slowed by the challenged regulations because they are forced to haul doubles across the State separately or around the State or to incur delays caused by using singles instead of doubles to pick up and deliver goods, and are prevented from accepting interline transfers of 65-foot doubles. In addition appellants' evidence showed that Wisconsin routinely allows a great number and variety of vehicles over 55 feet long to operate on state highways. A three-judge court ruled against appellants. Held: On the record, the challenged regulations violate the Commerce Clause because they place a substantial burden on interstate commerce
Was the commerce clause of the Federal Constitution (Art I, 8, cl 3) violated by Wisconsin regulations which generally prevent the operation on highways within the state of trucks longer than 55 feet and of double-trailer trucks--special permits for the operation of double-trailer trucks being restricted to limited circumstances not including general interstate operation of 65-foot double-trailer trucks by common carriers?
The court held that in view of the record in the case at bar, the regulations violated the commerce clause because they placed a substantial burden on interstate commerce and could not be said to make more than the most speculative contribution to highway safety, since (1) the state sought to justify the regulations solely as a safety measure because 65-foot double-trailer trucks took longer to pass or be passed than 55-foot single-trailer trucks, but the plaintiffs produced a massive array of evidence to disprove the state's assertion, including uncontradicted evidence that the difference in passing time did not pose an appreciable threat to motorists traveling on limited access, four-lane divided highways, (2) the plaintiffs, without contradiction, showed that the regulations imposed a substantial burden on the interstate movement of goods by substantially increasing the cost of such movement, by slowing the movement of goods in interstate commerce, and by preventing the plaintiffs from accepting interline transfers from other carriers of double-trailers for movement through the state, and (3) as another consideration, although not decisive, the regulatory scheme contained many exceptions to the general rule limiting vehicle length to 55 feet, some of which exceptions either discriminated on their face in favor of Wisconsin industries and against the industries of other states, or had been apparently enacted primarily for the benefit of important Wisconsin industries--the state having failed to make even a colorable showing that its regulations contributed to highway safety.