Minnesota v. Clover Leaf Creamery Co.

449 U.S. 456 (1981)

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Nature of the Case

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Facts

A Minnesota state statute prohibits retail distribution of nonreturnable or nonrefillable containers consisting of 50% plastic. The motive of the Minnesota legislature was to promote environmentally conscious solid waste disposal and conservation of energy. Opponents of the law maintain that the Act would not promote these goals but instead, increase costs of retail milk products and create an unwanted supply of nonreturnable and nonrefillable paper milk cartons. The Minnesota State Court ruled in favor of the Respondent-Clover Leaf, holding that the law was invalid because it disadvantaged the dairy and plastic industries while advantaging the pulpwood and local dairy establishments and thus violative of the Fourteenth Amendment, due process clause and equal prosecution clause and Minnesota law and under the Commerce Clause. The State appealed to the Supreme Court of Minnesota, which affirmed on the federal equal protection and due process grounds, without reaching the Commerce Clause or state law issues. The State Supreme Court found that the purpose of the Act was to promote the state interests of encouraging the reuse and recycling of materials and reducing the amount and type of material entering the solid waste stream and acknowledged the legitimacy of this purpose. Nevertheless, relying on the District Court's findings of fact, the full record, and an independent review of documentary sources, the State Supreme Court held that 'the evidence conclusively demonstrates that the discrimination against plastic nonrefillables is not rationally related to the Act's objectives.'