No, California's law is perfectly fine. The court decided that the 8% oil rule is not unfair because it applies to California's own avocado growers just as much as it applies to Florida's. It's a reasonable way for California to protect its consumers from buying bad avocados. The federal rule for Florida growers only says when their avocados are mature enough to be shipped out of state; it doesn't give them a free pass to ignore the sales rules of other states. Since the two rules don't contradict each other, California's law can stand.

No, the California rule is okay. It's not unfair or random, and it doesn't stop avocados from other states from being sold in California. The rule is there to make sure avocados are good to eat when people buy them. Also, the national law about when to pick avocados doesn't say that states can't check avocados themselves. The judges also said that state and national laws can both be followed without any problems.

Likewise, when the California District Court examined the avocado fat-content rule that had been challenged in Florida Lime, it considered whether California could achieve its goal to assure that California consumers bought ripe avocados by less restrictive means, including by using federal days-to-maturity and size standards).

"Both the State and the Federal requirements may be, and are being, enforced, without any clash between the two authorities. We are enjoined by the highest authority against seeking out conflict between state and Federal regulation, unless such conflict clearly exists***."

There was therefore, in the court's view, no conflict with the Michigan statute absolutely barring the sale of colored margarine, and whose purpose was to prevent deception and confusion.

—statute prohibiting sale in state of avocados containing less than 8% oil by weight protects consumers

—by Florida avocado growers to enjoin enforcement of the California law which requires avocados to contain not less than 8 per cent oil by weight excluding skin and seed.

—case correctly points out that there is a definite conflict between the two statutes, based on the fact that approximately six per cent of the Florida avocados are excluded from Califorma each year.

Neither the equal protection clause nor the privileges and immunities clause requires perfection in legislative classification.

It is nevertheless established that the states are not wholly precluded from exercising their police power in matters of local concern even though they may thereby indirectly affect interstate commerce.

A statutory enactment cannot be successfully attacked unless the discrimination or inequality produced by the particular classification is manifestly arbitrary, unreasonable, inequitable and unjust.

In considering these laws, the Supreme Court has time and again upheld state laws imposing stricter standards on foods.

No. The California law does not violate the Equal Protection Clause or the Commerce Clause, nor is it preempted by federal law. With respect to the Equal Protection Clause, the 8% oil standard is not arbitrary or unreasonable. The state has a legitimate interest in protecting consumers from immature fruit and ensuring a certain nutritional quality, and a single, uniform standard is a reasonable means of administration. Regarding the Commerce Clause, the law is a valid exercise of state police power that does not discriminate against interstate commerce; it applies equally to avocados grown in California and those grown elsewhere. Finally, there is no preemption because the federal marketing order for Florida avocados sets a minimum standard for shipment but does not occupy the entire regulatory field or create an exclusive federal standard for maturity that would prevent states from imposing their own, higher quality-control standards for sale.

No, the California law is not unconstitutional because it is not arbitrary or unreasonable and does not inherently discriminate against interstate commerce. The law serves a valid police purpose, and the enforcement is not discriminatory. The Federal Agricultural Marketing Agreement Act of 1937 does not preempt the California law, as it does not cover the entire field of avocado marketing and does not explicitly forbid state inspection standards. The court also noted that both state and federal requirements may be enforced without any clash between the two authorities.

Florida Lime and Avocado Growers, Inc. v. Paul

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