No, the federal rule does not overrule California's law. It's not impossible for Florida farmers to follow both rules; they can just leave their avocados on the trees longer until they have 8% oil. Also, Congress never said its rule was the only one allowed. States have always had the power to protect their own shoppers from being tricked into buying bad products, and the federal law didn't clearly take that power away.

Yes, the federal rule should be the only one that matters here. The situation is a mess: the federal government says an avocado is ready to sell everywhere, but California says 'not here.' This creates a direct conflict that gets in the way of what Congress wanted, which was a smooth, orderly market for avocados across the country. It makes no sense to have different ripeness tests in different states for the same fruit.

No, California's avocado law doesn't go against the federal rules because the state's law is about something that's really important for California and doesn't stop the federal government's plans from working. But we're not sure how this law affects selling things between states, so we need to check that part again.

Yes, California's avocado law does go against the federal rules because the federal government's plan covers everything about avocados and doesn't leave room for California's different law. California's law gets in the way of what Congress wants to do in controlling how ripe avocados need to be when they're sold to other states. The Court should have stopped California from enforcing its law against the Florida avocado growers.

—and (2) conflict preemption, "compliance with both federal and state regulations is a physical impossibility,"

State law is conflict-preempted when it is impossible to comply with both state law and federal law.

"Federal regulation... should not be deemed preemptive of state regulatory power in the absence of persuasive reasons either that the nature of the regulated subject matter permits no other conclusion, or that the Congress has unmistakably so ordained

Conflict preemption arises when (1) "compliance with both federal and state regulations is a physical impossibility," or (2) "when state law stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress." Id

—state law is preempted by federal law when "compliance with both federal and state regulations is a physical impossibility," for example, it would be physically impossible for a party to comply with both state and federal regulations if "the federal orders forbade the picking and marketing of any avocado testing more than 7% oil, which the California test excluded from the …

Based on the record at hand, the Court cannot conclude that the City is unable to fulfill simultaneously its overtime obligations under both state and federal law.

Where Congress has not acted to supersede completely regulation by the states, state law is nullified to the extent that it conflicts with federal law.

State laws will survive such a challenge unless there is "such actual conflict between the two schemes of regulation that both cannot stand in the same area,[or] evidence of a congressional design to preempt the field."

No, the Agricultural Adjustment Act and its marketing orders do not preempt the California statute. Federal regulation of a field of commerce does not preempt state police power in the absence of a clear congressional mandate, an irreconcilable conflict, or a physical impossibility of dual compliance. Here, there is no physical impossibility, as Florida growers can comply with both standards by leaving their avocados on the trees longer to develop the required oil content. Furthermore, Congress did not demonstrate a 'clear and manifest purpose' to displace state law; the Agricultural Adjustment Act establishes minimum standards for orderly marketing at the production end, but does not oust the states' traditional power to protect their consumers from deception and fraud at the retail end. The state's interest in preventing the sale of immature, unpalatable fruit is a legitimate exercise of its police powers that does not stand as an obstacle to the federal scheme.

Yes, the California statute is preempted because it stands as an obstacle to the accomplishment of the full purposes of Congress. The federal government established a comprehensive regulatory scheme to determine the maturity of Florida avocados, certifying them as fit for all interstate markets. California's conflicting standard directly undermines this by rejecting fruit the federal government has deemed mature, thereby disrupting the orderly marketing Congress sought to achieve. The purpose of both laws is identical—to prevent the sale of immature fruit—but they use conflicting tests. This conflict creates a substantial barrier to interstate commerce and frustrates the federal objective of applying uniform standards to facilitate the flow of agricultural goods.

No, the California statute does not unconstitutionally conflict with federal marketing orders under the Supremacy Clause because the maturity of avocados is a matter of peculiarly local concern and the federal marketing orders do not preempt the field to the exclusion of the state statute. The state regulation does not stand as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress. However, the effect of the statute upon interstate commerce cannot be determined on the current record, and the case is remanded for a new trial on the Commerce Clause challenge.

Yes, the California statute unconstitutionally conflicts with the federal marketing orders under the Supremacy Clause because the federal regulatory scheme is comprehensive and pervasive, leaving no room for the state regulation. The state law stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress in regulating the maturity and quality of avocados to be transported in interstate commerce. The judgment should be reversed with instructions to grant the injunction requested by the Florida growers.

Florida Lime & Avocado Growers, Inc. v. Paul, Director, Dept. of Agriculture of California

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