| Venue: | SCOTUS |
| Facts: | Minnesota bans the sale of milk in plastic containers: only paperboard
cartons are allowed. This is said to be for the reduction of plastic
waste, but maybe it just drives up the cost of milk.
Anyway, modern industrial concerns are mad. |
| Posture: | Initial injunctive relief for defendants at trial. MN SC agrees: the act is void on substantive due process (14A) grounds, as well as interstate commerce grounds. |
| Issue: | Does legislative discrimination between plastic and cardboard containers have a rational relationship to the stated purpose of the law (reduction of waste, and stomping out plastic milk containers before they become entrenched in the marketplace)? |
| Holding: | Yes. Reversed. |
| Rule: | The court doesn't question whether the legislature is correct-- only whether the enactment has a rational relationship to its purpose. |
| Reasoning: | The fact that a law is mistaken isn't grounds for getting it
overturned by the court (i.e., as unconstitutional). It is
not the function of the courts to substitute their judgment
for that of the legislature.
Simple economic protectionism is invalid in all of its guises. Even if it's evenhanded, if the burden imposed on interstate commerce is excessive in relation to the putative local benefits, it must be struck down. But here, we've got in-state interests that are affected just like the out-of-state ones. And we're not talking about a major inconvenience. And this does directly relate to the stated purpose of the legislation, so there's no interstate commerce issue here, and therefore also no due process or equal protection issues. |
| Dicta: | |