Mayo v. United States

Background

Florida’s law required inspection stamps and fees on commercial fertilizer bags to assure quality and protect land. The federal Department of Agriculture bought fertilizer outside Florida and sent it into the State for a soil-conservation program, distributing sacks without the state stamps. Florida’s Commissioner ordered a ‘stop sale,’ and the United States sued to block enforcement of the state law so the federal distribution could continue.

Reasoning

The Court considered whether the federal government must pay state inspection fees on fertilizer it owned and distributed. It found the United States owned the fertilizer and was acting in a governmental capacity under the soil-conservation program. Relying on the Constitution’s rule that federal law must be dominant over state law, the Court held that requiring payment of these fees would burden a federal function and that the United States is therefore immune from the state regulation in this situation.

Real world impact

The ruling means the federal government can supply fertilizer for its conservation program in Florida without paying the state inspection fees or affixing state stamps. That protects the timing and operation of the national soil-conservation plan and prevents state fees from disrupting federally run distributions. The decision affirms that federal activities carried out by the United States itself are not subject to state exactions unless Congress says otherwise.

Dissents or concurrances

A Justice concurred in the result; at the district court level one judge had dissented. The concurrence simply agreed with the outcome rather than adding a separate legal rule.