Pennsylvania v. Virginia
Headline: West Virginia law forcing in-state natural gas to be sold locally is struck down, blocking the state from diverting supplies and protecting interstate gas shipments to neighboring states.
Holding: The Court ruled that West Virginia’s law forcing in-state priority for natural gas unlawfully regulates interstate commerce and is therefore invalid, preventing the State from diverting gas shipments to neighboring states.
- Prevents a state from blocking gas shipments to other states.
- Keeps interstate gas sales and pipeline deliveries protected from state preference laws.
- Allows affected states to get preventive relief before threatened supply cuts occur.
Summary
Background
Pennsylvania and Ohio sued to stop a West Virginia law that required natural gas produced in West Virginia to be used to satisfy West Virginia consumers before any interstate shipments. The law was passed February 10, 1919, took effect May 11, and the two states filed suit eight days later by direction of their legislatures; initial injunctions were granted and remain in place. The dispute arose because diminishing supplies meant West Virginia might cut deliveries to Ohio and Pennsylvania.
Reasoning
The Court asked whether a State may, by its own law, withdraw a natural product from an established interstate flow of commerce. The majority held that natural gas transmitted from one State to another is an article of interstate commerce and that a state law whose necessary operation prevents or burdens that transmission is a forbidden regulation of interstate commerce. The Court noted the health and welfare of private consumers were jeopardized and that preventive relief was appropriate. It also said pipeline companies and benefited in‑state consumers need not be made parties to the suit.
Real world impact
The decision declares the West Virginia act void and prevents the State from giving a legal preference that would stop gas shipments to other states. The ruling protects interstate sales and pipeline deliveries and allows affected states to seek court relief before threatened supply cuts occur. The opinion rests on the Constitution’s allocation of power over interstate commerce to the national government.
Dissents or concurrances
Justices Holmes, McReynolds, and Brandeis dissented. Holmes said a State may regulate products before they enter commerce and may favor its own citizens; McReynolds and Brandeis contended the Court lacked a proper case, necessary parties were missing, and the Court should not intervene to help discriminatory corporate practices.
Opinions in this case:
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