Florida Lime & Avocado Growers, Inc. v. Paul
1963 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Florida Lime & Avocado Growers, Inc. v. Paul, 373 U.S. 132 (1963), was a 1963 decision of the United States Supreme Court in which the Court declined to invalidate a California law that imposed minimum fat content standards on avocados sold in the state, including those imported from other states.[1] The law prohibited the sale of avocados that did not contain at least 8% oil by weight. Florida, a major avocado producer, employed, for wholesale marketing purposes, a federal standard unrelated to oil content. Most Florida avocados that were marketable at home failed to meet the California standard, because they were a different variety from those sold in California, with a lower fat content. Accordingly, Florida avocado growers brought this suit, arguing (unsuccessfully) that the California law (1) was preempted by federal law, (2) violated equal protection, and (3) unduly burdened and interfered with their right to engage in interstate commerce. The case is widely used in law school casebooks on constitutional law and federal jurisdiction as illustrative of preemption issues.[2]
Florida Lime & Avocado Growers, Inc. v. Paul | |
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Argued January 8, 1963 Decided May 13, 1963 | |
Full case name | Florida Lime & Avocado Growers, Inc., et al. v. Paul, Director of the Department of Agriculture of California, et al. |
Citations | 373 U.S. 132 (more) 83 S. Ct. 1210; 10 L. Ed. 2d 248; 1963 U.S. LEXIS 1617 |
Case history | |
Prior | Complaint dismissed, Fla. Lime & Avocado Growers, Inc. v. Jacobsen, 169 F. Supp. 774 (N.D. Cal. 1958), reversed, 362 U.S. 73 (1960); injunction denied on remand, Fla. Lime & Avocado Growers, Inc. v. Paul, 197 F. Supp. 780 (N.D. Cal. 1961); probable jurisdiction noted, 368 U.S. 964 (1962). |
Subsequent | Rehearing denied, 374 U.S. 858 (1963). |
Holding | |
California Agricultural Code § 792 neither violates the Supremacy Clause nor the Equal Protection Clause. | |
Court membership | |
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Case opinions | |
Majority | Brennan, joined by Warren, Harlan, Stewart, Goldberg |
Dissent | White, joined by Black, Douglas, Clark |