Pike v. Bruce Church, Inc.

Facts

Bruce Church, Inc. grew, harvested, processed and packed fruits and vegetables in Arizona and California for shipment to markets across the Nation. Under a 1964 lease, it developed about 6,400 acres of arid land at Parker, Arizona, and spent more than $3,000,000 on that work. It began growing cantaloupes there in 1966. The melons were considered of higher quality than others grown in the State. They were highly perishable and had to be harvested, packed and shipped right away, and packing could be done only in packing sheds. The company had no sheds at Parker, so it transported its 1966 and 1967 crops in bulk to its packing sheds at Blythe, California, 31 miles away. There the melons were sorted, inspected, packed and shipped in containers that bore the name of the California packer, not Arizona. With certain exceptions, Arizona's Fruit and Vegetable Standardization Act required cantaloupes grown in the State to be packed in closed standard containers approved by the state supervisor. In 1968, Pike, the official who enforced the Act, ordered the company not to ship its cantaloupes out of the State unless they were packed as approved. No packing sheds were available nearby in Arizona, so the company faced the loss of its 1968 crop, worth $700,000. Complying meant building packing facilities near Parker at a cost of about $200,000. The State said its primary purpose was to protect the reputation of Arizona growers by prohibiting deceptive packaging.

Issues

1. Does an Arizona order that bars a grower from shipping cantaloupes out of the State unless they are packed in Arizona burden interstate commerce, even though it regulates only the packing done before shipment?
2. Can Arizona constitutionally force a grower to build a $200,000 packing plant in the State when the State's only interest is having the grower's high-quality cantaloupes identified as Arizona produce?

Holding

Arizona could not constitutionally require the company to build and run an unneeded $200,000 packing plant in the State just so its high-quality cantaloupes would be identified as Arizona produce. The State's interest was minimal at best and could not justify a burden whose nature mattered more than its extent, so the order was invalid.