Hunt v. Washington State Apple Advertising Commission

Background

A state agency that promotes Washington apples challenged a North Carolina law that required closed apple containers to show only the U.S. (USDA) grade or be marked unclassified, and that forbade state grading labels. Washington is a major apple producer with a mandatory grading and inspection system; its industry uses preprinted containers showing Washington grades. North Carolina’s rule forced growers to obliterate labels, repack, or stop using preprinted containers, causing added costs and lost accounts for Washington growers and dealers. The Washington State Apple Advertising Commission sued, and a three-judge federal court blocked the labeling ban as unconstitutional.

Reasoning

The Court addressed whether the labeling rule unfairly burdened interstate trade. It agreed with the lower court that the North Carolina law, though facially neutral, discriminated against Washington sellers by raising their costs and stripping away the competitive advantages of Washington’s inspection and grading system. The Court found the rule did little to protect consumers — it even allowed ungraded containers — and noted readily available, less discriminatory alternatives, like requiring both state and USDA grades or banning only inferior state grades. Because North Carolina failed to justify the discriminatory effect, the Court affirmed the injunction against enforcing the ban on Washington State grades.

Real world impact

The ruling lets Washington growers continue using their state grades when shipping apples to North Carolina, preserving established marketing practices and avoiding routine repackaging expenses. It limits states’ ability to adopt labeling rules that effectively exclude out-of-state producers and protects the free national market in agricultural goods.