Maine v. Taylor

Background

Maine, its wildlife agency, a bait seller named Robert Taylor, and the federal government are at the center of this case. Taylor arranged to import about 158,000 live golden shiners into Maine despite a state law barring imported live bait. A federal grand jury indicted him under the Lacey Act for importing in violation of state law. The District Court upheld Maine’s ban, the First Circuit reversed, and Maine appealed to this Court.

Reasoning

The Court considered whether Maine’s flat import ban unlawfully blocks interstate trade under the Constitution’s commerce rule and whether the Lacey Act changed that test. The Justices treated the ban as discriminatory against out‑of‑state goods and applied the rule that a State may justify such discrimination only by proving a legitimate local purpose and the lack of workable nondiscriminatory alternatives. The Supreme Court deferred to the District Court’s factual findings that parasites and nonnative species could harm Maine’s fisheries and that reliable sampling or inspection methods for baitfish were not yet available, so the ban could stand and federal prosecution under the Lacey Act was permissible.

Real world impact

The ruling allows Maine to continue blocking imported live baitfish and permits federal enforcement when state wildlife laws are violated. Bait dealers who import minnows from other States face criminal risk while accepted testing or certification methods remain undeveloped. If reliable inspection techniques are later created, Maine’s ban could lose its constitutional support.

Dissents or concurrances

Justice Stevens dissented, warning that Maine’s unique, flat ban looked like economic protectionism and argued that uncertainty about risks and alternatives should defeat such clear discrimination against out‑of‑state commerce.