City of Philadelphia v. New Jersey
Encyclopedia
City of Philadelphia v. New Jersey, , was a case in which the Supreme Court of the United States
held that states could not discriminate against another state's articles of commerce.
. In writing for the majority, Justice Stewart
concluded that
In other words, New Jersey couldn't regulate beyond its borders.
Furthermore, the court held that legitimate local interests which had incidental interstate effects were within the state's general police powers, but "where simple economic protectionism is effected by state legislation, a virtually per se rule of invalidity has been erected".
"The physical fact of life that New Jersey must somehow dispose of its own noxious items does not mean that it must serve as a depository for those of every other state."
Because states can rightfully burden interstate commerce in the name of health and safety, Rehnquist found no hindrance to this law in the Commerce Clause.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that states could not discriminate against another state's articles of commerce.
Court's Findings
The Court found a New Jersey law prohibiting the importation of most "solid or liquid waste which originated or was collected outside the territorial limits of the State" unconstitutional because it violated the Dormant Commerce ClauseDormant Commerce Clause
The "Dormant" Commerce Clause, also known as the "Negative" Commerce Clause, is a legal doctrine that courts in the United States have inferred from the Commerce Clause in Article I of the United States Constitution...
. In writing for the majority, Justice Stewart
Potter Stewart
Potter Stewart was an Associate Justice of the United States Supreme Court. During his tenure, he made, among other areas, major contributions to criminal justice reform, civil rights, access to the courts, and Fourth Amendment jurisprudence.-Education:Stewart was born in Jackson, Michigan,...
concluded that
- "whatever New Jersey's ultimate purpose, it may not be accomplished by discriminating against articles of commerce coming from outside the State unless there is some reason, apart from their origin, to treat them differently."
In other words, New Jersey couldn't regulate beyond its borders.
Furthermore, the court held that legitimate local interests which had incidental interstate effects were within the state's general police powers, but "where simple economic protectionism is effected by state legislation, a virtually per se rule of invalidity has been erected".
Dissent
Justice Rehnquist, joined by Justice Burger, maintained that the law was constitutional, on the basis of the validity of quarantine laws. Rehnquist reasoned that the toxic trash New Jersey handled from out-of-state was no different than diseased meat and germ-infected rags that were legally prohibited in quarantine laws."The physical fact of life that New Jersey must somehow dispose of its own noxious items does not mean that it must serve as a depository for those of every other state."
Because states can rightfully burden interstate commerce in the name of health and safety, Rehnquist found no hindrance to this law in the Commerce Clause.
See also
- Chemical Waste Management, Inc. v. HuntChemical Waste Management, Inc. v. HuntChemical Waste Management, Inc. v. Hunt, 504 U.S. 334 , was a United States Supreme Court case that held that an Alabama law imposing a fee on out-of-state hazardous waste being disposed of in-state violated the Dormant Commerce Clause...
- Environmental dumpingEnvironmental dumpingEnvironmental dumping is the practice of transfrontier shipment of waste from one country to another. The goal is to take the waste to a country that has less strict environmental laws, or environmental laws that are not strictly enforced...
- List of United States Supreme Court cases, volume 437