Tigner v. Texas

Background

A man named Tigner was indicted under a Texas criminal law for conspiring to fix retail beer prices. He challenged the law because it expressly exempts agricultural products and livestock when in the hands of the producer or raiser. The Texas Court of Criminal Appeals had upheld the statute, and Tigner argued that an older Supreme Court case, Connolly v. Union Sewer Pipe Co., showed such an exemption violates the Fourteenth Amendment’s guarantee of equal protection.

Reasoning

The central question was whether Texas may punish business combinations by criminal law while excluding farmers from that punishment. The Court found that long-standing legislative distinctions between agriculture and industry, and federal and state laws supporting farmer cooperation, meant treating farmers differently was within legislative power. The opinion explained that the Constitution does not demand identical legal treatment for different economic activities and that legislatures may also choose different remedies, like civil penalties instead of criminal sanctions. On that basis the Court held the exemption constitutional and affirmed the lower court’s decision.

Real world impact

The decision means farmers and farm cooperatives are less likely to face criminal prosecution for collective pricing in Texas, though civil penalties can still apply. It recognizes broad legislative authority to treat agriculture differently and signals that older case law rejecting such exemptions is no longer controlling.

Dissents or concurrances

Justice McReynolds disagreed and would have reversed the judgment below.