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Separate plaintiffs who wanted to be able to ship their wines directly to consumers in the states sued for discriminatory practices. Both trial courts ruled for the plaintiffs, but the sixth court of appeals ruled for the plaintiffs in Michigan while the Second Court of Appeals ruled for the defendants in New York. The Supreme Court consolidated the appeals.
Issue – Are the states imposing an undue burden on out of state wineries that gives an unfair advantage to in state competitors? Does the Burden violate the commerce clause?Ruling – Both laws are invalidatedRationale – The Supreme Court has always held that differential treatment of in-state and out of state economic interests that benefits the former at the expense of the latter violate the Commerce Clause. The systems set up by Michigan and New York obviously establish discriminatory policies which put out of state wineries at a disadvantage. While the states might not have set out to discriminate against commerce, they created a burden which directly conflicted with congress’ charge to regulate interstate commerce. Other State Limitations Article IV, Section 1 of the constitution provides that “full faith and credit shall be given in each state to the public acts, records, and judicial proceedings of every other stateExceptions:a)If a court didn’t have jurisdiction to rule on matter other courts aren’t obligated to respectthe rulingb)If the judgement violates the public policy of the state where enforcement is soughtArticle I, section 10 of the constitution provides that “no state shall pass any law impairing the obligation of contractsa)State laws passed covering contracts include a grandfather clause specifying that the law only effects contracts signed after its passageb)Only effects state governments, not the federal government Protecting Basic RightsThe bill of rights applies only to the federal government, not to state or local governmentsThe 14thamendment’s due process clause has been used to apply almost all of the provisions within the bill of rights to state and local governments Protective provisions within the constitution are aimed only at the government and don’t limit individuals actions Privileges and Immunities Article IV, section 2 of the constitution provides that “the citizens of each state shall be entitled to all the privileges and immunities of the several states”, preventing the governments of states from discriminating against residents of other states based solely on their residency Applies exclusively to individuals and not corporationsHas exceptions, courts weigh discrimination against the need it purports to fillFreedom of ReligionThe first amendment contains 2 clauses which aim to protect the freedom of religion
a)Congress shall not pass any laws respecting an establishment of a religionb)Congress shall not prohibit the free exercise thereofFreedom of Speech