Fla. Lime & Avocado Growers, Inc. v. Paul

373 U.S. 132, 83 S. Ct. 1210 (1963)

 

RULE:

Whether a State may constitutionally reject commodities which a federal authority has certified to be marketable depends upon whether the state regulation stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress.

FACTS:


Appellant avocado growers and handlers challenged the constitutionality of Cal. Agric. Code § 792 insofar as it was applied by appellee government to exclude certain out-of-state avocados from California. The district court held that § 792 was constitutional.Appellants contended that § 792 of the California statute, as so applied, was unconstitutional, because under the Supremacy Clause, it must be deemed displaced by the federal standard for determining the maturity of avocados grown in Florida; The United States Supreme Court affirmed the judgment regarding appellants' challenges under U.S. Const. art. VI (Supremacy Clause) and U.S. Const. amend. XIV (Equal Protection Clause) and reversed the judgment as to the U.S. Const. art. I, §8 (Commerce Clause) challenge.

ISSUE:

Is § 792 of the California Agricultural Code invalid under the Supremacy Clause?

ANSWER:

No.

CONCLUSION:

Cal. Agric. Code § 792 did not violate the Supremacy Clause because compliance with § 792 and the Agricultural Adjustment Act (the Act), 7 U.S.C.S. § 608c(3) and (4), was not impossible, the subject matter of Cal. Agric. Code § 792 was not subject to exclusive federal regulation, and Congress did not intend the Act to displace state regulations. Section 792 did not violate the Equal Protection Clause because it was not arbitrary or devoid of rational relationship to a legitimate regulatory interest. The record was insufficient for the Court to determine whether § 792 violated the Commerce Clause; thus, that portion of the judgment was reversed and remanded.

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