## Facts

- Michigan’s Solid Waste Management Act required each county to adopt a solid waste management plan controlling landfill operations.
- The Act barred landfills from accepting solid waste generated outside the receiving county (including from other states) unless the county plan expressly authorized such disposal.
- St. Clair County’s plan did not authorize acceptance of out-of-county or out-of-state waste.
- Fort Gratiot Sanitary Landfill, a private landfill in St. Clair County, sought county approval to accept waste from outside the county; the county denied the request under the Act and the county plan.
- Fort Gratiot sued in federal court, seeking declaratory and injunctive relief on the ground that the restrictions violated the Commerce Clause.
- The district court dismissed the complaint, and the Sixth Circuit affirmed, reasoning the law did not facially discriminate because it treated out-of-county Michigan waste and out-of-state waste the same.
- The Supreme Court granted review.

## Issues

1. Whether Michigan’s county-by-county default prohibition on disposal of out-of-county (including out-of-state) solid waste, unless affirmatively allowed by the receiving county’s plan, discriminates against interstate commerce in violation of the dormant Commerce Clause.
2. Whether a state may avoid dormant Commerce Clause limits by delegating to political subdivisions authority to exclude articles of commerce from outside the subdivision.

## Decision

- The Supreme Court reversed the Sixth Circuit and held the Waste Import Restrictions unconstitutional.
- The Court found the restrictions unambiguously discriminatory because they permitted counties to protect local waste generators by blocking access to local disposal facilities for out-of-county waste unless the county opted in.
- Equal treatment of out-of-county in-state waste and out-of-state waste did not cure the discrimination; a state cannot sidestep Commerce Clause constraints by implementing barriers through subdivisions.
- Because the law was discriminatory, it was subject to a virtually per se rule of invalidity and could survive only if Michigan showed a legitimate local purpose that could not be served by reasonable nondiscriminatory alternatives.
- Michigan’s asserted environmental and capacity-management goals could be addressed through nondiscriminatory regulation (e.g., uniform capacity limits or operational standards), and Michigan did not prove such alternatives were inadequate.

## Legal Principles

- A law that discriminates against interstate commerce is generally invalid unless the state proves the measure serves a legitimate local purpose that cannot be achieved through reasonable nondiscriminatory alternatives.
- A state may not isolate local markets from interstate competition by restricting the movement of articles of commerce based on geographic origin.
- A state cannot evade dormant Commerce Clause limits by delegating exclusionary or protectionist authority to local political subdivisions.
- Environmental and public health interests may be pursued through origin-neutral regulations governing landfill capacity, safety, and operating conditions.

## Conclusion

The Court invalidated Michigan’s county-based waste import restrictions because they discriminated against interstate commerce by organizing access to disposal markets along local lines, and Michigan failed to justify the discrimination as necessary to achieve legitimate local goals unavailable through nondiscriminatory measures.


Fort Gratiot Sanitary Landfill, Inc. v. Mich. Dep’t of Nat. Res., 504 U.S. 353 (1992)