Pike v. Bruce Church, Inc.

Background

A commercial farming company growing cantaloupes on leased land in Parker, Arizona, shipped its harvest 31 miles to Blythe, California, for sorting, packing, and shipment because it had no packing sheds at Parker. An Arizona official, enforcing a state law that requires certain packing standards and containers, ordered the company not to ship uncrated cantaloupes out of Arizona. The company sued in federal court and an emergency injunction was granted to prevent imminent loss of the 1968 crop, later becoming a permanent injunction.

Reasoning

The Court considered whether the Arizona order unconstitutionally burdened interstate trade. The State’s law aims to prevent deceptive packaging and protect the reputation of Arizona growers, a legitimate local interest. But applying the law to this company would force it to pack its fruit inside Arizona and effectively require construction of a $200,000 packing plant. The opinion explains that a state cannot require businesses to perform operations at home when those operations are more efficiently done elsewhere, because such a requirement places an undue and almost per se illegal burden on interstate shipping.

Real world impact

The Court affirmed the lower court’s injunction, blocking enforcement of the order against this company. That means this farmer can continue shipping perishable cantaloupes to an out-of-state packer rather than being forced to build in-state facilities. The ruling protects businesses that rely on efficient, out-of-state packing for perishable goods and limits a State’s power to use packaging rules to redirect business activity.