Raymond Motor Transportation, Inc. v. Rice
1978 U.S. LEXIS 46, 54 L. Ed. 2d 664, 434 U.S. 429 (1978)
Rule of Law:
A state's highway safety regulation violates the dormant Commerce Clause if it imposes a substantial burden on interstate commerce and the state fails to present credible evidence that the regulation makes more than a speculative contribution to safety.
Facts:
- Raymond Motor Transportation and Consolidated Freightways are interstate common carriers that sought to operate 65-foot double-trailer trucks ('doubles') for efficiency.
- The companies' most direct routes for shipping commodities between major Midwest hubs, such as Chicago and Minneapolis, pass through Wisconsin.
- Surrounding states, including Illinois and Minnesota, as well as all states to the west, permitted the operation of 65-foot doubles on their interstate highways.
- Wisconsin law generally prohibited trucks longer than 55 feet and required a special permit for any vehicle pulling more than one trailer.
- Wisconsin's administrative regulations for such permits were extremely narrow, granting them for hauling items like municipal waste or milk, but not for general interstate freight, thus effectively banning the companies' trucks.
- Due to Wisconsin's regulations, the companies were forced to use less efficient 55-foot single trucks, break down their doubles at the state border to be hauled as single units, or reroute their trucks around the state, incurring substantial delays and costs.
Procedural Posture:
- Raymond and Consolidated applied to Wisconsin officials for annual permits to operate 65-foot double-trailer trucks, which were denied.
- The companies filed suit against Wisconsin officials in the U.S. District Court for the Western District of Wisconsin, seeking declaratory and injunctive relief.
- A three-judge District Court was convened to hear the case.
- The District Court held that the Wisconsin regulations were not unconstitutional and entered judgment in favor of the state.
- Raymond and Consolidated, the appellants, filed a direct appeal to the Supreme Court of the United States, with Wisconsin officials as the appellees.
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Issue:
Do Wisconsin's administrative regulations, which effectively ban 65-foot double-trailer trucks from its highways, violate the Commerce Clause by imposing a burden on interstate commerce that is clearly excessive in relation to the state's putative safety benefits?
Opinions:
Majority - Mr. Justice Powell
Yes, Wisconsin's regulations violate the Commerce Clause. Under the balancing test from Pike v. Bruce Church, Inc., a non-discriminatory state regulation will be upheld unless the burden it imposes on interstate commerce is clearly excessive in relation to the putative local benefits. While state highway safety regulations are afforded a strong presumption of validity, that presumption was overcome here. The trucking companies produced an 'overwhelming' and uncontradicted record showing that 65-foot doubles are as safe as, if not safer than, the 55-foot single trucks Wisconsin allows. In contrast, Wisconsin 'virtually defaulted' in its defense, offering no evidence to support its safety claim beyond the speculative assertion that longer trucks take longer to pass. The regulations impose a substantial burden on commerce through increased costs, delays, and rerouting, and the state's maze of exemptions for local industries undermines its claimed safety rationale. Therefore, the burden is clearly excessive compared to the regulations' 'most speculative contribution' to highway safety.
Concurring - Mr. Justice Blackmun
Yes. This holding is narrow and does not signal a new judicial willingness to second-guess legitimate state safety regulations. This case is exceptional because Wisconsin's asserted safety justification is 'illusory.' The Court is not balancing a real safety interest against commercial burdens; rather, it is concluding that, as a matter of law, the state failed to demonstrate that any real safety interest exists. The state's practice of granting thousands of permits for other oversized vehicles to benefit local Wisconsin industries further proves that the state itself does not genuinely believe such vehicles pose a significant safety threat.
Analysis:
This decision refines the application of the Pike balancing test to state highway safety laws, an area where states traditionally receive significant deference. The Court established that the strong presumption of validity for safety regulations is rebuttable and can be overcome by overwhelming, uncontradicted evidence that the law provides no actual safety benefit. The case stands as a key precedent for challenging state regulations that act as protectionist trade barriers under the pretext of safety, placing the evidentiary burden on a state to justify a regulation that substantially impedes interstate commerce.
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