[T]he state standard does not work an "irrational discrimination as between persons or groups of persons"
Florida Lime & Avocado Growers, Inc. v. Paul
California law requires avocados sold in California to be at least 8% oil. Federal law gauges avocado maturity in unrelated ways. Plaintiffs, avocado farmers from Florida, couldn't consistently get their avocados up to 8% oil, even when mature.
The federal standard for avocado maturity preempts the California standard.
Applying the California statute to Floridian avocados violates the Equal Protection Clause of the Fourteenth Amendment.
The California statute is unreasonably burdensome on interstate commerce in violation of the Commerce Clause.
District court denied injuction, finding:
- The federal standard didn't conflict with California's or prohibit further regulation by the states by occupying the whole field.
- The statute applied equally to California and Florida growers.
- The statute only kept unpalatable avocados out of California, and most Florida avocados met the test.
Was the California statute preempted by the federal standards?
Does the California standard violate the Equal Protection Clause?
Is the California standard unreasonably burdensome on interstate commerce?
Congress was only trying to get producers to figure out common procedures, not end all local regulations.
- Page 152, II
Just because California has a legitimate interest in having high-quality avocados doesn't mean it isn't discriminatory or burdensome. There's no understanding of whether the district court admitted plaintiff's key evidence or not when making this decision.
Plaintiff didn't show an Supremacy Clause violation.
Plaintiff didn't show an Equal Protection violation.
We can't decide based on evidence that may or may not admitted.
Reversed and remanded for new trial on Commerce Clause.
: The California Statute is an obstacle to the federal scheme. This should be reversed and the injuction granted.
The Supreme Court calls avocados "fruit" throughout this case.