Florida Lime & Avocado Growers, Inc. v. Paul

373 U.S. 132



When a state and federal statute exist with different standards, as long as both statutes can coexist, the Supreme Court of the United States will not decide whether or which one preempts the other.


California's Agricultural Code prohibits the transportation or sale in the state of avocados which contain "less than 8% of oil, by weight standards, weight excluding the skin and seed." On the other hand, Federal marketing orders approved by the Secretary of Agriculture gage the maturity of avocados grown in Florida by standards, which attribute no significance to the oil content. This means that CA markets FL avocados which satisfy Federal law, but not California law. Plaintiffs challenged the law under the Constitution's Supremacy and Commerce clauses.


Did the statute violate the US constitution?


The statute did not violate the Supremacy Clause; there was insufficient evidence regarding the Commerce clause.


The Court held that there is no need to look into Congressional intent if "compliance with both federal and state regulations is a physical impossibility for one engaged in interstate commerce." Since there was no present record regarding the Commerce clause issue, the case was remanded. 

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