Sage Stores Co. v. Kansas Ex Rel. Mitchell

Background

A Kansas state official sued a Kansas grocery seller and a Michigan food maker to stop them from selling a canned "filled milk" product in Kansas. The Kansas law banned milk products to which any fat or oil other than milk fat had been added. A Kansas court found the companies’ product looked and tasted like evaporated whole milk and that ordinary consumers could not tell the difference without chemical tests.

Reasoning

The Court considered whether Kansas’ ban was arbitrary or an unreasonable interference with property and liberty protected by the Fourteenth Amendment. The state introduced evidence that, while the product was harmless and nutritious for adults with varied diets, it lacked certain fatty acids, sterols, and vitamins and did not support infant growth as well as whole milk. The legislature also aimed to prevent fraud where the product was indistinguishable from whole milk. Applying the same standards used in similar cases, the Court found a rational basis for the ban and upheld the law.

Real world impact

The ruling allows Kansas to continue preventing the manufacture and sale of these filled-milk compounds within the State. It upholds state authority to ban food products that the legislature reasonably finds inferior or misleading, especially where infant nutrition is at stake. This decision is final on the constitutional question presented here.

Dissents or concurrances

Justices Black and Douglas agreed with the outcome but their separate views were not elaborated in the opinion; they joined only in the result.