## Facts

- Minnesota enacted a 1977 law barring retail sale of milk in plastic nonreturnable, nonrefillable containers while allowing other nonreturnable containers, including paperboard cartons.
- The legislature stated environmental objectives: resource conservation, easing solid-waste disposal problems, and conserving energy.
- The ban applied evenhandedly to milk and containers regardless of whether produced in Minnesota or out of state.
- Dairies and plastic-container interests challenged the law, alleging it was protectionist and not meaningfully connected to the stated environmental goals.
- After evidentiary hearings, a trial court enjoined enforcement, finding the classification against plastic nonreturnables not rationally related to the statute’s objectives.
- The Minnesota Supreme Court affirmed on federal equal protection grounds and did not decide the Commerce Clause issue.

## Issues

1. Whether banning plastic nonreturnable, nonrefillable milk containers while permitting other nonreturnable containers violates the Equal Protection Clause under rational-basis review.
2. Whether the statute violates the dormant Commerce Clause by discriminating against interstate commerce or imposing burdens on interstate commerce that are clearly excessive relative to local benefits.

## Decision

- The U.S. Supreme Court reversed and upheld the statute.
- The Court held the classification satisfied equal protection because the legislature could rationally believe the ban might advance conservation and solid-waste goals.
- The Court held the statute did not discriminate against interstate commerce and imposed only incidental burdens not clearly excessive in relation to asserted local environmental benefits.
- The Court rejected the argument that the state was constitutionally required to adopt a less restrictive regulatory alternative.

## Legal Principles

- Economic and social legislation not involving suspect classifications or fundamental rights is reviewed under rational-basis scrutiny and carries a strong presumption of validity.
- Under rational-basis review, a law is valid if legislators could rationally believe the classification might further legitimate governmental objectives; courts do not resolve contested policy evidence by substituting their judgment for the legislature’s when the matter is debatable.
- Equal protection permits incremental regulation; a state may address a problem “one step at a time” and may allow established practices to continue while regulating a newer category first, so long as the line drawn is not arbitrary.
- A facially neutral, evenhanded state regulation affecting interstate commerce is evaluated under Pike balancing and is upheld unless incidental burdens are clearly excessive in relation to putative local benefits.
- The dormant Commerce Clause generally does not impose a “least restrictive means” requirement on nondiscriminatory state regulation.

## Conclusion

The Court sustained Minnesota’s plastic milk-container ban, holding that the legislature’s environmentally motivated classification was rational under the Equal Protection Clause and that the law’s incidental effects on interstate commerce were permissible under Pike because they were not clearly excessive compared to the state’s asserted conservation and waste-disposal benefits.


Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456 (1981)