Milk Control Bd. v. Eisenberg Farm Prods.

332 Pa. 34, 200 A. 854 (1938)

 

RULE:

While Supreme Court of Pennsylvania feels that state laws regulating transactions incidental to interstate commerce but designed to protect the health, safety, or welfare of the public are proper state regulation where the transaction, which is the origin and beginning of the commerce, is peculiarly within the state's domain, the Supreme Court of the United States has held that such regulations are a burden on interstate commerce and that the states are forbidden to legislate thereon, even though the federal government has taken no steps to protect the public from the danger of fraud. The Supreme Court of Pennsylvania is controlled by them on matters affecting interstate commerce. 

FACTS:

A farm products company bought milk from farmers, cooled it, and shipped it within 24 hours to New York City for resale there. The Milk Control Board (Board) of Pennsylvania brought an action under the Milk Control Law of Pennsylvania against the farm products company, which operated a milk receiving plant. The Board sought to require the company to secure a license and to submit to its regulations. Contrary to the Board's claims, the trial court found that it was not possible to separate the company's purchase of the milk in Pennsylvania from the shipment of the milk to New York City so as to characterize the purchase as a purely intrastate transaction that was subject to the Milk Control Law and the Board's jurisdiction. It ruled in favor of the company and the Board appealed.

ISSUE:

Should company be subject to the Milk Control Law of Pennsylvania where it bought milk, strictly for shipment to New York?

ANSWER:

No

CONCLUSION:

The court affirmed the trial court, indicating a belief that state laws regulating transactions that were incidental to interstate commerce were proper under the circumstances. The court stated that licensing and bonding were necessarily related to the preservation of an adequate milk supply and were in the interests of public health. The court nevertheless ruled that it was bound by United States Supreme Court decisions to the contrary that held that such regulations were a burden on interstate commerce and that the states were forbidden to legislate in the area, even though the federal government took no steps to protect the public from fraud. The court also concluded that the trial court had adequately covered all of the federal issues in its opinion.

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