WEST LYNN CREAMERY V. HEALY 512 U.S. 186 (1994) CASE BRIEF

WEST LYNN CREAMERY V. HEALY

512 U.S. 186 (1994)

NATURE OF THE CASE: This was a dispute over state dairy subsidies and whether they violate the Commerce Clause.

FACTS: The order at issue requires every 'dealer' in Massachusetts to make a monthly 'premium payment' into the 'Massachusetts Dairy Equalization Fund.' Each month the fund is distributed to Massachusetts producers. Each Massachusetts producer receives a share of the total fund equal to his proportionate contribution to the State's total production of raw milk. Petitioners West Lynn and LeComte's (P) complied with the pricing order for two months, paying almost $200,000 into the Massachusetts Dairy Equalization Fund. Ps then refused to make the premium payments, and respondent commenced license revocation proceedings. Ps then filed an action in state court seeking an injunction against enforcement of the order on the ground that it violated the Commerce Clause. The state court denied relief and respondent conditionally revoked their licenses. The Supreme Judicial Court of Massachusetts affirmed, because it concluded that 'the pricing order does not discriminate on its face, is evenhanded in its application, and only incidentally burdens interstate commerce.' It conceded that '[c]ommon sense' indicated that the plan has an 'adverse impact on interstate commerce,' and that 'the fund distribution scheme does burden out-of-State producers. The Court asserted that 'the burden is incidental, given the purpose and design of the program.' The Supreme Court granted certiorari.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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