| Florida Lime & Avocado Growers, Inc. v. Paul | ||||||
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Supreme Court of the United States |
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| Argued January 8, 1963 Decided May 13, 1963 |
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| Full case name | Florida Lime & Avocado Growers, Inc., et al. v. Paul, Director of the Department of Agriculture of California, et al. | |||||
| Holding | ||||||
| California Agricultural Code §792 neither violates the Supremacy Clause nor the Equal Protection Clause. | ||||||
| Court membership | ||||||
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| Case opinions | ||||||
| Majority | Brennan, joined by Warren, Harlan, Stewart, Goldberg | |||||
| Dissent | White, joined by Black, Douglas, Clark | |||||
In Florida Lime & Avocado Growers, Inc. v. Paul, 373 U.S. 132 (1963),[1] the Supreme Court of the United States declined to invalidate a California law that imposed minimum maturity standards on avocados sold in the state, including those imported from other states. The law prohibited the retail sale of avocados that did not contain at least 8% oil by weight. Florida, a major avocado producer, employed, for wholesale marketing purposes, a federal standard unrelated to oil content. Many Florida avocados that were marketable at home failed to meet the California standard, so Florida avocado growers brought this suit, arguing that the California law (1) was preempted by federal law, (2) violated equal protection, and (3) interfered with their right to engage in interstate commerce.
The Florida growers lost at trial when the three-judge district court dismissed the case on jurisdictional grounds, finding that there was not a current justiciable case or controversy. They appealed directly to the U.S. Supreme Court, which found the case justiciable and then held that the California law did not conflict with the federal law and was not preempted by it. First, there was no direct conflict between the federal and state statutes because it was possible to comply with both standards simultaneously; second, the California law did not frustrate the purpose of the federal law, which was to "do no more than promote orderly competition among the South Florida growers." The Court then found that the California law did not violate equal protection, and it remanded the case to the trial court for more fact-finding on the third claim, whether the California law impermissibly burdened interstate commerce. Primarily because of the preemption holding and the court's definition of "direct conflict," this case is a staple in law school casebooks on constitutional law and federal jurisdiction.