Granholm v. Heald
Following is the case brief for Granholm v. Heald, 540 U.S. 460 (2005)
Case Summary of Granholm v. Heald:
- Michigan and New York allowed in-state wineries to ship directly to consumers, but limited out-of-state wineries from doing the same. Separate lawsuits against both States were instituted.
- On appeal, the Sixth Circuit Court of Appeals struck down the Michigan law, but the Second Circuit Court of Appeals upheld the New York law.
- The U.S. Supreme Court consolidated the cases and struck down both laws as unconstitutional. The Court held that discriminating against interstate commerce violated the Commerce Clause, and the 21st Amendment did not save the laws from that violation.
Granholm v. Heald Case Brief
Statement of the Facts:
The States of Michigan and New York allowed in-state wineries to ship wine directly to consumers, but limited out-of-state wineries from doing the same. Although the regulatory schemes differed slightly between the States, both States essentially set up costly barriers for out-of-state wineries to reach consumers in their States, which were not required of in-state wineries. The object and design of the regulation in both States was to give a competitive advantage to in-state wineries.
Lawsuits in both States were filed, in which out-of-state wineries and some consumers claimed that the difference in treatment was a violation of the Commerce Clause. The States claimed that they were permitted to regulate in that manner based upon the authority of the 21st Amendment.
- In the Michigan case, the District Court upheld Michigan’s regulatory scheme. The Sixth Circuit Court of Appeals, however, reversed. The Sixth Circuit held that the regulatory scheme violated the Commerce Clause.
- In the New York case, another District Court struck down New York’s regulatory scheme. The Second Circuit Court of Appeals, however, reversed. The Second Circuit held that the 21st Amendment allowed New York’s law.
- The U.S. Supreme Court consolidated the cases and granted certiorari.
Issue and Holding:
Does a State’s regulation that allows in-state wineries to ship directly to consumers but restricts out-of-state wineries from doing the same violate the Commerce Clause in light of the 21st Amendment? Yes.
The Sixth Circuit judgment is affirmed, and the Second Circuit judgment is reversed.
Rule of Law or Legal Principle Applied:
A State law that discriminates between in-state and out-of-state alcoholic products violates the Commerce Clause and is neither authorized nor permitted by the 21st Amendment.
The Court has consistently held that state laws violate the Commerce Clause if they require different treatment of in-state and out-of-state economic interests to benefit the former. Here, there is little question that Michigan and New York’s laws discriminate against interstate commerce in violation of the Commerce Clause.
The States’ argument that their laws are saved by the 21st Amendment is unavailing based on Court precedent and the Amendment’s history. The aim of the 21st Amendment was to uniformly control the distribution and use of liquor, not discriminate against out-of-state alcohol producers. Further, modern 21st Amendment cases hold that the Amendment does not save state laws that violate other provisions of the Constitution.
Dissenting Opinion (Stevens):
The Michigan and New York laws would clearly be invalid if the discussion was about a product other than alcohol. However, the 18th and 21st Amendments put the distribution of alcohol in a special category. As such, the 21st Amendment’s broad authority should allow Michigan and New York’s laws to stand.
Dissenting Opinion (Thomas):
A careful reading of the history of the 21st Amendment, and the fact that Congress passed legislation to overrule certain Court decisions when the Amendment was first ratified, demonstrate that the Court is wrong to invalidate the laws in this case.
Granholm v. Heald is significant because it involves an extended discussion of the history and Court decisions surrounding the 21st Amendment, an Amendment that is rarely invoked.