RAYMOND MOTOR TRANSPORTATION, INC. V. RICE
434 U.S. 429 (1980)
NATURE OF THE CASE: This was a dispute over the administrative regulations of the State
of Wisconsin governing the length and configuration of trucks that may be operated within
the State and whether they violate the Commerce Clause because they unconstitutionally
burden or discriminate against interstate commerce.
FACTS: Appellant Raymond is a common carrier of general commodities by motor vehicle.
Raymond provides service in eastern North Dakota, Minnesota, northern Illinois, and
northwestern Indiana. Its primary interstate route is between Chicago and Minneapolis. It
does not serve any points in Wisconsin. Appellant Consolidated is a common carrier of
general commodities by motor vehicle. Consolidated operates nationwide, providing service
under a certificate of public convenience and necessity in 42 States and Canada. Among other
routes, Consolidated carries commodities between Chicago, Detroit, and points east, and
Minneapolis and points west to Seattle. Consolidated does carry commodities between
Wisconsin and other States, and it maintains terminals in Milwaukee and Madison where
truckloads of goods are dispatched and received. Both Raymond and Consolidated use two
different kinds of trucks. One consists of a three-axle power unit (tractor) which pulls a
single two-axle trailer that is 40 feet long. The overall length of such a single-trailer
unit (single) is 55 feet. This unit has been used on the Nation's highways for many years
and is an industry standard. The other type truck consists of a two-axle tractor which pulls
a single-axle trailer to which a single-axle dolly and a second single-axle trailer are
attached. Each trailer is 27 feet long, and the overall length of such a double-trailer unit
(double) is 65 feet. Because of logistics advantages, both companies would prefer to use
doubles. Wisconsin law, however, generally does not allow trucks longer than 55 feet to be
operated on highways within that State without a permit. Both Raymond and Consolidated each
applied to the appropriate Wisconsin officials under 348.27 (6) for annual permits to
operate 65-foot doubles. The permits were denied because appellants' proposed operations
were not within the narrow scope of the administrative regulations that specify when
'trailer train' permits will be issued. Appellants then filed suit in Federal District Court
seeking declaratory and injunctive relief on the ground that the regulations barring the
proposed operation of 65-foot doubles burden and discriminate against interstate commerce in
violation of the Commerce Clause, Art. I, 8, cl. 3. The State's amended answer advanced
highway safety as its sole justification. Appellants presented a great deal of evidence
supporting their allegation that 65-foot doubles are as safe as, if not safer than, 55-foot
singles when operated on limited-access, four-lane divided highways. The State, for reasons
unexplained, made no effort to contradict this evidence of comparative safety with evidence
of its own. The court found that the Wisconsin regulatory scheme does not discriminate
against interstate commerce. The court also considered 'whether the burden imposed upon
interstate commerce outweighs the benefits to the local populace,' and concluded that it did
not. Appellants contend that the State's refusal to issue the requested 'trailer train'
permits under 348.27 (6) burdens interstate commerce in violation of the Commerce Clause
because it substantially interferes with the movement of goods in interstate commerce and
makes no contribution to highway and they argue that 348.27 (4), authorizing issuance of
'interplant' permits, discriminates against interstate commerce in violation of the Commerce
Clause because it allows permits to be issued to carry the products of Wisconsin industries,
but not of other States' industries, over Wisconsin highways in trucks longer than 55 feet.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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