Florida Lime & Avocado Growers, Inc. v. Paul
Encyclopedia
In Florida Lime & Avocado Growers, Inc. v. Paul, 373 U.S. 132
(1963), the Supreme Court of the United States
declined to invalidate a California
law that imposed minimum maturity standards on avocados sold in the state, including those imported from other states. The law prohibited the retail 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. Many Florida avocados that were marketable at home failed to meet the California standard, so Florida avocado growers brought this suit, arguing that the California law (1) was preempted by federal law, (2) violated equal protection, and (3) interfered with their right to engage in interstate commerce.
The Florida growers lost at trial when the three-judge district court dismissed the case on jurisdictional grounds, finding that there was not a current justiciable case or controversy. They appealed directly to the U.S. Supreme Court, which found the case justiciable and then held that the California law did not conflict with the federal law and was not preempted by it. First, there was no direct conflict between the federal and state statutes because it was possible to comply with both standards simultaneously; second, the California law did not frustrate the purpose of the federal law, which was to "do no more than promote orderly competition among the South Florida growers." The Court then found that the California law did not violate equal protection, and it remanded the case to the trial court for more fact-finding on the third claim, whether the California law impermissibly burdened interstate commerce. Primarily because of the preemption holding and the court's definition of "direct conflict," this case is a staple in law school casebooks on constitutional law and federal jurisdiction.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1963), the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
declined to invalidate a California
California
California is a state located on the West Coast of the United States. It is by far the most populous U.S. state, and the third-largest by land area...
law that imposed minimum maturity standards on avocados sold in the state, including those imported from other states. The law prohibited the retail sale of avocados that did not contain at least 8% oil by weight. Florida
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
, a major avocado
Avocado
The avocado is a tree native to Central Mexico, classified in the flowering plant family Lauraceae along with cinnamon, camphor and bay laurel...
producer, employed, for wholesale marketing purposes, a federal standard unrelated to oil content. Many Florida avocados that were marketable at home failed to meet the California standard, so Florida avocado growers brought this suit, arguing that the California law (1) was preempted by federal law, (2) violated equal protection, and (3) interfered with their right to engage in interstate commerce.
The Florida growers lost at trial when the three-judge district court dismissed the case on jurisdictional grounds, finding that there was not a current justiciable case or controversy. They appealed directly to the U.S. Supreme Court, which found the case justiciable and then held that the California law did not conflict with the federal law and was not preempted by it. First, there was no direct conflict between the federal and state statutes because it was possible to comply with both standards simultaneously; second, the California law did not frustrate the purpose of the federal law, which was to "do no more than promote orderly competition among the South Florida growers." The Court then found that the California law did not violate equal protection, and it remanded the case to the trial court for more fact-finding on the third claim, whether the California law impermissibly burdened interstate commerce. Primarily because of the preemption holding and the court's definition of "direct conflict," this case is a staple in law school casebooks on constitutional law and federal jurisdiction.