Overview
The Supreme Court upheld California's Proposition 12, finding it does not violate the dormant Commerce Clause, as the law does not purposefully discriminate against interstate commerce nor imposes clearly excessive burdens compared to its local benefits.
Background and Legal Challenge
- California voters passed Proposition 12, restricting the sale of pork from animals confined outside California standards.
- Pork industry associations argued Proposition 12 unduly burdened interstate commerce through its extraterritorial effects.
- Lower courts dismissed the challenge, finding no plausible claim under the dormant Commerce Clause.
Supreme Court Decision
- The Court affirmed the Ninth Circuit's dismissal, holding Proposition 12 does not violate the dormant Commerce Clause.
- State laws cannot discriminate against or unduly burden interstate commerce but are not per se invalid for extraterritorial effects if not purposefully discriminatory.
- The Pike v. Bruce Church, Inc. balancing test was applied; the law's burdens were not clearly excessive relative to local benefits.
Opinions of the Justices
- Justice Gorsuch wrote the majority opinion, joined in parts by Justices Thomas, Sotomayor, Kagan, and Barrett.
- Justice Sotomayor (joined by Kagan): Petitioners failed to show a substantial burden on interstate commerce.
- Justices Thomas and Barrett: Although a substantial burden was alleged, the law's benefits and burdens can't be meaningfully compared.
- Chief Justice Roberts (joined by Alito, Kavanaugh, Jackson): Argued for vacating the judgment and remanding, as a substantial burden was alleged and more analysis was needed.
- Justice Kavanaugh: Raised the possibility of additional constitutional challenges under other clauses.
Decisions
- Proposition 12 does not violate the dormant Commerce Clause: The Supreme Court upheld California’s law and affirmed the lower court’s decision.