Florida Lime & Avocado Growers, Inc. v. Paul

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Florida Lime & Avocado Growers, Inc. v. Paul, 373 U.S. 132 (1963),^[1] was a case in which the Supreme Court of the United States upheld a California law that imposed minimum ripeness standards on avocados imported into the state. The law barred retail sale of avocados that didn't meet the ripeness standard, which was measured by standard oil content. Florida, which grows a lot of avocados, used a federal standard of ripeness for wholesale marketing purposes. Florida brought this suit to oppose the California law, which it argued discouraged their right to engage in interstate commerce.

In this case, the preemption doctrine failed because the court held that simultaneous compliance was possible. The Court employed a dormant commerce clause analysis and held that the law was not overly burdensome to interstate commerce. The Court found the California law to "do no more than promote orderly competition among the South Florida growers."