Facts of the Case
Minnesota enacted a statute prohibiting the sale of milk and milk products in non-refillable, non-returnable plastic containers. Clover Leaf Creamery sued to overturn the law. A Minnesota District Court found that the statute did not fulfill the legislature's purpose. The Minnesota Supreme Court affirmed the decision.
Questions
Did the Minnesota statute violate the Commerce clause of Article I or the Equal Protection clause of the Fourteenth Amendment?
Conclusions
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No and no. Writing for the majority in a 7-1 decision, Justice William J. Brennan Jr. maintained that Minnesota's statute was not unconstitutional, acknowledging that the legislature had an interest in promoting resource conservation and resolving solid waste disposal issues. The difference between non-reusable plastic containers and paper or reusable plastic containers was "rationally related" to the legislature's purpose, and therefore not unconstitutional under the rational basis test set forth in New Orleans v. Dukes. The statute banned sale of all milk in the specified containers and did not distinguish by seller, and therefore did not violate the commerce clause. Justice Powell wrote an opinion concurring in part and dissenting in part.
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