United States Brewers Association v. Abe Rodriguez

Background

Brewers and other makers of malt beverages (beer) sued New Mexico after the State extended a price-affirmation law in 1979 to cover beer. The law limited the price producers could charge wholesalers by tying it to prices charged in other States. A state trial court upheld the 1979 amendment, and the New Mexico Supreme Court affirmed. While that appeal was pending, the legislature repealed and replaced the law in 1981 with a slightly different timing rule.

Reasoning

The narrow question before the U.S. Supreme Court was whether the appeals raised a substantial federal question worth review. The Court concluded they did not and dismissed the appeals. The Court agreed with the state courts’ reliance on earlier decisions that supported price-affirmation laws and noted that the New Mexico Supreme Court had not ruled on the 1981 replacement law, so the U.S. Supreme Court would not consider it. In short, the dismissal leaves the state-court judgment upholding the 1979 amendment in place.

Real world impact

As a result, the state-court decision upholding the 1979 price rule remains effective for now, and beer producers must operate under that outcome unless the issue is properly raised again. The U.S. Supreme Court did not make a final decision about the 1981 replacement statute, so questions about that newer law could be litigated later if presented to and decided by the state courts.

Dissents or concurrances

Justice Stevens wrote a concurrence explaining these points and agreeing to dismiss. Justice Powell took no part in the decision.