## Facts

- Arizona’s Fruit and Vegetable Standardization Act required most Arizona-grown cantaloupes offered for sale to be packed in closed standard containers approved by a state supervisor.
- Bruce Church, Inc. grew cantaloupes in Parker, Arizona, but had no packing facilities there.
- The company shipped uncrated cantaloupes about 30–31 miles to Blythe, California, where they were sorted, inspected, packed, and shipped in containers bearing the California packer’s name.
- An Arizona official, Loren J. Pike, ordered the company to stop transporting uncrated cantaloupes from Parker to Blythe, effectively requiring in-state packing.
- Compliance would have forced Bruce Church to build and operate packing facilities in or near Parker at an estimated cost of $200,000 to pack an approximately $700,000 crop.
- Arizona asserted the order was needed to ensure the cantaloupes were identified as Arizona-grown and to protect the reputation of Arizona growers.

## Issues

1. Whether Arizona’s in-state packing requirement, as applied to force construction of an otherwise unnecessary packing facility, imposed an unconstitutional burden on interstate commerce under the Dormant Commerce Clause.
2. Whether a facially nondiscriminatory state regulation with only incidental effects on interstate commerce can be invalid when the burden on commerce is clearly excessive relative to the state’s asserted benefits.

## Decision

- The Supreme Court affirmed the federal district court’s permanent injunction against enforcement of Pike’s order.
- The Court held that the order imposed a substantial burden on interstate commerce by requiring an out-of-state packing operation to be relocated into Arizona.
- Although Arizona had a legitimate interest in protecting the reputation of its growers and preventing deceptive packaging, that interest was relatively minor in this application.
- The burden of compelling a $200,000 capital expenditure to achieve marginal benefits was clearly excessive in relation to the state’s asserted interest.
- The order therefore violated the Dormant Commerce Clause.

## Legal Principles

- When a state law regulates evenhandedly to further a legitimate local public interest and has only incidental effects on interstate commerce, it is valid unless the burden on interstate commerce is clearly excessive in relation to the putative local benefits.
- If a legitimate local purpose exists, constitutionality turns on degree: the tolerable burden depends on the nature of the local interest and whether the interest could be served with a lesser impact on interstate commerce.
- A state may not, for slight local benefits, compel a business to restructure its interstate operations by shifting processing or packing into the state.

## Conclusion

The Court invalidated Arizona’s application of its cantaloupe packing requirement because the substantial forced cost of in-state packing was clearly excessive compared to the state’s limited interest in origin identification, and it articulated the balancing framework used to assess nondiscriminatory state regulations that incidentally burden interstate commerce.


Pike v. Bruce Church, Inc., 397 U.S. 137 (1970)