Heath & Milligan Manufacturing Co. v. Worst

Background

A group of paint manufacturers who sell mixed paints in North Dakota challenged a state law that aims to prevent the adulteration of and deception in the sale of white lead and mixed paints. The law requires makers of white lead and certain mixed paints to list the percent of each mineral and to show true composition, and it requires substitutes for linseed oil to be declared. The manufacturers say the law unfairly burdens them, brands some paints as adulterated, and favors paints made with certain listed ingredients.

Reasoning

The Court considered whether the classification was arbitrary. It said states may make reasonable distinctions to prevent deception and that the Constitution does not require perfect wisdom or precise remedies. The Court found the statute’s labeling rules related to its consumer-protection purpose and that any imperfections, like failing to set exact ingredient proportions or using imprecise terms, showed incompleteness not unconstitutionality. The Court also explained that the law does not forbid non-listed ingredients; it simply requires that their use be declared.

Real world impact

Because of the ruling, some mixed-paint makers must add ingredient labels and declare substitutes when selling in North Dakota, which increases production and labeling costs for those firms. Consumers will see more information about what is in paints, and manufacturers may still use non-enumerated materials so long as they disclose them. The decision leaves room for administrative correction of vague terms and assumes legislative judgment about which ingredients the public regards as standard.