Hunt v. Wash. State Apple Ad. Comm.

Case Date: 02/22/1977
Docket No: none

Facts of the Case 

In 1972, the North Carolina Board of Agriculture adopted a regulation that required all apples shipped into the state in closed containers to display the USDA grade or nothing at all. Washington State growers(whose standards are higher than the USDA) challenged the regulation as an unreasonable burden to interstate commerce. North Carolina stated it was a valid exercise of its police powers to create "uniformity" to protect its citizenry from "fraud and deception."

Question 

Did the North Carolina regulation violate the Commerce Clause by placing an unreasonable burden on interstate commerce?

Argument Hunt v. Wash. State Apple Ad. Comm. - Oral ArgumentFull Transcript Text  Download MP3Hunt v. Wash. State Apple Ad. Comm. - Opinion Announcement  Download MP3 Conclusion  Decision: 8 votes for Wash. State Apple Ad. Comm., 0 vote(s) against Legal provision: Article 1, Section 8, Paragraph 3: Interstate Commerce Clause

The Court voted unanimously that the North Carolina regulation was an unconstitutional exercise of the state's power over interstate commerce. Although the regulation was facially neutral, it had a discriminatory impact on the Washington growers while shielding the local growers from the same burden. The regulation removed the competitive advantage gained by the Washington apples from stricter inspection standards. The regulation produced a leveling effect that works to the local advantage by "downgrading" apples from other states unjustly. Therefore, the regulation places an unreasonable burden on interstate commerce.