Pike v. Bruce Church, Inc.
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Case Overview
CITATION
ARGUED ON
DECIDED ON
DECIDED BY
397 U.S. 137
Jan. 13, 1970
Mar. 2, 1970
Legal Issues
Did Arizona’s regulation of cantaloupe processing place an unconstitutional burden on interstate commerce?
Holding
Yes, Arizona’s regulation of cantaloupe processing placed an burden on interstate commerce and was unconstitutional under the dormant commerce clause doctrine.
Vintage label for Bruce Church, Inc. | Credit: thelabelman.com
Background
Bruce Church, Inc. was a company that grew cantaloupes in Parker, Arizona. The company began growing cantaloupes in Parker in 1966, and harvested its cantaloupe crop there each year since. Their cantaloupes are considered to be of higher quality than the rest of those grown in other areas of the State. Because they’re highly perishable, cantaloupes must be immediately harvested, processed, packed, and shipped in order to prevent spoilage upon maturity. This process can only take place in packing sheds. Since the company didn’t have any packing sheds in Parker, it transported its cantaloupes to its nearby facilities in California, where they were sorted, inspected, packed, and shipped in containers with the label of the California packer. In 1967, the company again sent its cantaloupe crop from Parker to Blythe for sorting, packing, and shipping.
In 1968, James Pike, the Supervisor of Inspection for the Arizona Fruit and Vegetable Standardization Service, ordered the company to stop shipping its cantaloupes outside the State unless they were packed in containers in a manner approved by the State. Pike argued that his order was necessary to ensure that the cantaloupes could be identified as originating from Arizona. The company sued for injunctive relief, arguing that Pike’s order was an unconstitutional burden on interstate commerce. The District Court issued an injunction against Pike, preventing enforcement of his order. Pike appealed, and the Supreme Court granted certiorari.
Unanimous decision for Bruce Church, Inc.
Pike
Bruce Church, Inc.
Burger
Stewart
Brennan
Marshall
White
Douglas
Black
Harlan II