Bibb v. Navajo Freight Lines, Inc.

359 U.S. 520 (1959)

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Nature of the Case

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Facts

Illinois (D) passed a statute requiring the use of a certain type of rear fender mudguard on trucks. Appellees challenged the constitutionality of the Act. A specially constituted three-judge District Court concluded that it unduly and unreasonably burdened and obstructed interstate commerce because it made the conventional or straight mudflap, which is legal in at least 45 States, illegal in Illinois, and because the statute, taken together with a Rule of the Arkansas Commerce Commission requiring straight mudflaps, rendered the use of the same motor vehicle equipment in both States impossible. Thus, carriers operating into or through Illinois would be required to equip all their trailers in accordance with the requirements of the Illinois Splash Guard statute. With two possible exceptions, the mudflaps required in those States which have mudguard regulations would not meet the standards required by the Illinois statute. The cost of installing the contour mudguards is $30 or more per vehicle. The initial cost of installing those mudguards on all the trucks owned by Navajo (P) ranged from $4,500 to $45,840. The cost of maintenance and replacement of these guards is substantial. The District Court held that the contour mudflap possesses no advantages over the conventional or straight mudflap previously required in Illinois and presently required in most of the states and that 'there is rather convincing testimony that use of the contour flap creates hazards previously unknown to those using the highways.' The statute was declared to be violative of the Commerce Clause, and D was enjoined from enforcing it.