Florida Lime & Avocado Growers, Inc. v. Paul

Supreme Court of the United States, 1963
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Facts:

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.

Plaintiff's Arguments:

  • 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.

Procedural History:

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.

Issues:

  • 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?

Reasoning:

  • Congress was only trying to get producers to figure out common procedures, not end all local regulations.

  • WestLaw LogoLexisNexis IconGoogle Scholar LogoPage 152, II

    [T]he state standard does not work an "irrational discrimination as between persons or groups of persons"

  • 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.

Holding:

  • 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.

Judgment:

Reversed and remanded for new trial on Commerce Clause.

Dissenting Opinion:

White: The California Statute is an obstacle to the federal scheme. This should be reversed and the injuction granted.

Note:

The Supreme Court calls avocados "fruit" throughout this case.