GRANHOLM V. HEALD
544 U.S. 460 (2005)
NATURE OF THE CASE: Heald (P) sued Granholm (D), state officials, alleging that state
laws discriminated against out-of-state wineries in violation of U.S. Const. art. I, 8,
cl. 3.
FACTS: New York and Michigan, regulate the sale and importation of alcoholic beverages,
including wine, through a three-tier distribution system. Separate licenses are required for
producers, wholesalers, and retailers. Each D in their own way allows in-state wineries to
sell wine directly to consumers in that State but prohibits out-of-state wineries from doing
so, or, at the least, to make direct sales impractical from an economic standpoint. This
discrimination substantially limits the direct sale of wine to consumers, an otherwise
emerging and significant business. Approximately 26 States allow some direct shipping of
wine, with various restrictions. Thirteen of these States have reciprocity laws, which allow
direct shipment from wineries outside the State, provided the State of origin affords
similar nondiscriminatory treatment. Many states prohibit or severely restrict direct
shipments depriving consumers of access to the direct market. Ps are small wineries that
rely on direct consumer sales as an important part of their businesses. Ps, Michigan
residents, sued D claiming that its direct-shipment laws discriminated against interstate
commerce in violation of the Federal Constitution's commerce clause (Art I, 8, cl 3). The
District Court granted summary judgment to D. The Court of Appeals reversed and remanded,
concluded that (1) the Constitution's Twenty-first Amendment--prohibiting the transportation
or importation of intoxicating liquors into any state in violation of that state's laws--did
not immunize all state liquor laws from the strictures of the commerce clause; and (2) the
Michigan scheme was unconstitutional, because the defendants had failed to demonstrate that
the state could not meet its proffered policy objectives through nondiscriminatory means.
Ps, New York residents, sued D seeking a declaration that New York's direct-shipment laws
violated the commerce clause. The District Court granted Ps summary judgment. The Court of
Appeals for the Second Circuit reversed and concluded that New York's laws fell within the
ambit of the state's powers under the Twenty-first Amendment. The Supreme Court, having
consolidated these cases and granted certiorari.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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