undue-burden claim

The State of Iowa maintains a statute that restricts most truck combinations on its highways to 55 feet in overall length while allowing 60-foot doubles, 60-foot singles hauling livestock or farm equipment, and 65-foot singles. Consolidated Freightways Corporation of Delaware, a major common carrier operating in 48 states under an Interstate Commerce Commission certificate, regularly transports goods through Iowa on Interstate 80 and Interstate 35 using both 55-foot singles and 65-foot doubles. Because Iowa bars 65-foot doubles, Consolidated must either switch to shorter permitted vehicles, detach and shuttle the trailers separately, or divert its longer rigs around the state entirely, adding roughly $2 million per year to its own operating costs and an estimated $12.6 million annually to the industry as a whole. Iowa's length limits originated in a 1947 uniformity statute and were set at 60 feet in 1963. In 1974 the legislature passed a bill raising the limit to 65 feet for doubles. Governor Ray vetoed it, stating that the change would benefit out-of-state trucking firms at the expense of Iowa citizens. The legislature then enacted a border-cities exemption allowing municipalities abutting other states to adopt the neighboring state's longer limits. Additional exemptions permit Iowa truck manufacturers to ship 70-foot units and allow oversized mobile homes when moved from or to points inside the state. Consolidated filed suit in the United States District Court for the Southern District of Iowa seeking declaratory and injunctive relief. After a 14-day trial that included comparative accident data, braking and maneuverability tests, and testimony from state and federal transportation officials, the District Court found that 65-foot doubles were as safe as the vehicles Iowa permits. The court further found that the length restriction caused affected trucks to travel more miles over more dangerous roads in other states, increasing overall accidents, injuries, fatalities, fuel consumption, and highway wear. The Court of Appeals for the Eighth Circuit affirmed. Iowa appealed, and the Supreme Court noted probable jurisdiction. At trial Consolidated introduced 1978 accident statistics showing that its 65-foot doubles, driven 56 million miles on identical routes, produced 106 accidents with 17 injuries and one fatality, while its 55-foot singles produced 100 accidents with 27 injuries and one fatality. Iowa's own Department of Transportation study concluded that 65-foot twins had not been shown to be less safe than 60-foot twins or conventional semis. Iowa presented evidence that longer vehicles take more time to pass and clear intersections. Iowa also showed that longer trucks are somewhat more prone to jackknifing. No witness testified that 65-foot doubles were more dangerous overall than the trucks the state allows.

Dean Milk Co. is an Illinois corporation engaged in distributing milk and milk products in Illinois and Wisconsin. It challenged two sections of an ordinance of the City of Madison, Wisconsin, regulating the sale of milk and milk products within the municipality's jurisdiction. One section made it unlawful to sell any milk as pasteurized unless it had been processed and bottled at an approved pasteurization plant within a radius of five miles from the central square of Madison. Another section prohibited the sale of milk or the importation, receipt or storage of milk for sale in Madison unless from a source of supply possessing a permit issued after inspection by Madison officials, but expressly relieved municipal authorities from any duty to inspect farms located beyond twenty-five miles from the center of the city. Dean Milk Co. purchased and gathered milk from approximately 950 farms in northern Illinois and southern Wisconsin, none being within twenty-five miles of Madison. Its pasteurization plants were located at Chemung and Huntley, Illinois, about sixty-five and eighty-five miles respectively from Madison. The company was denied a license to sell its products within Madison solely because its pasteurization plants were more than five miles away. The milk it sought to sell was supplied from farms and processed in plants licensed and inspected by public health authorities of Chicago and labeled Grade A under the Chicago ordinance adopting the rating standards recommended by the United States Public Health Service. The City of Madison is the county seat of Dane County, within which are some 5,600 dairy farms with total raw milk production in excess of 600,000,000 pounds annually and more than ten times the requirements of Madison. The area defined by the ordinance with respect to milk sources encompassed practically all of Dane County and included some 500 farms which supply milk for Madison. Within the five-mile area for pasteurization were plants of five processors, only three of which were engaged in the general wholesale and retail trade in Madison. Inspection of these farms and plants was scheduled once every thirty days and was performed by two municipal inspectors, one of whom was full-time. Dean Milk Co. contended below that both the five-mile limit on pasteurization plants and the twenty-five-mile limit on sources of milk violated the Commerce Clause and the Fourteenth Amendment to the Federal Constitution. The Supreme Court of Wisconsin upheld the five-mile limit on pasteurization and ordered the complaint dismissed for want of a justiciable controversy as to the twenty-five-mile limitation. Dean Milk Co. appealed, contesting both rulings and invoking the jurisdiction of the United States Supreme Court under 28 U.S.C. § 1257(2). The Health Commissioner of Madison testified that he had submitted the provisions in controversy and an alternative proposal based on section 11 of the Model Milk Ordinance recommended by the United States Public Health Service, which imposes no geographical limitation on location of milk sources and processing plants but excludes milk not produced and pasteurized conformably to standards as high as those enforced by the receiving city. Both the Health Commissioner and the milk sanitarian of the Wisconsin State Board of Health agreed that a local health officer would be justified in relying upon the evaluation by the Public Health Service of enforcement conditions in remote producing areas.

In March 1992, Alfonso Lopez, Jr., a twelfth-grade student at Edison High School in San Antonio, Texas, arrived at school carrying a concealed .38-caliber handgun and five bullets. Acting on an anonymous tip, school authorities confronted Lopez, who admitted possessing the weapon. Local police arrested him and charged him under Texas law with firearm possession on school premises. The following day, state charges were dismissed after federal agents charged Lopez with violating the Gun-Free School Zones Act of 1990. A federal grand jury indicted him on one count of knowing possession of a firearm at a school zone. Lopez moved to dismiss the indictment, arguing that the statute exceeded Congress's power to legislate control over public schools. The district court denied the motion, concluding that the statute was a constitutional exercise of Congress's power to regulate activities affecting commerce because the business of schools affects interstate commerce. After a bench trial, the court found Lopez guilty and sentenced him to six months' imprisonment and two years of supervised release. Lopez appealed to the Court of Appeals for the Fifth Circuit, which reversed the conviction, holding that the statute was beyond Congress's power under the Commerce Clause. The Supreme Court granted certiorari to review the case.