State of Minnesota v. Clover Leaf Creamery Co. (1981)

Case Name: State of Minnesota v. Clover Leaf Creamery Co. (1981)

Facts: Minnesota wanted to discourage the use of nonreturnable, nonrefillable containers for the packaging of milk to combat a solid waste management problem for the state. However, the statute banned the retail sale of milk in plastic but permitted other nonreturnable, nonrefillable containers such as paperboard.

Procedural History: The lower court found that (contrary to the statement of purpose) the actual basis for the Act was to promote the economic interests of certain segments of the local dairy and pulpwood industries at the expense of the economic interests of other segments of the dairy and plastics industry.

Holding: The Act is constitutional because the statue does not discriminate between interstate and intrastate commerce and the incidental burden imposed on interstate commerce is not “clearly excessive in relation to the putative local benefits.”

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