South Carolina State Highway Dept. v. Barnwell Bros., Inc.
303 U.S. 177 (1938)
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Rule of Law:
In the absence of conflicting federal legislation, a state may impose non-discriminatory size and weight restrictions on vehicles using its highways to promote public safety and road conservation, and such regulations do not impose an unconstitutional burden on interstate commerce if they are rationally related to that purpose.
Facts:
- In 1933, the South Carolina General Assembly enacted Act No. 259.
- The Act prohibited the use of motor trucks on state highways that were wider than 90 inches.
- The Act also prohibited trucks whose gross weight, including their load, exceeded 20,000 pounds.
- At the time, 85% to 90% of motor trucks used in interstate commerce were 96 inches wide.
- Most interstate trucks, when loaded, exceeded the 20,000-pound gross weight limit.
- The vast majority of other states permitted a truck width of 96 inches.
- Compliance with South Carolina's law would seriously impede and increase the cost of motor truck traffic passing through the state.
Procedural Posture:
- Barnwell Brothers, Inc., along with other truckers and shippers, filed suit in the U.S. District Court for the Eastern District of South Carolina against the South Carolina State Highway Department.
- The suit sought to enjoin the enforcement of the state's truck width and weight restrictions.
- A three-judge district court ruled that the statute placed an unlawful burden on interstate commerce.
- The district court issued an injunction preventing the state from enforcing the weight and width provisions against interstate motor carriers on specified highways.
- The South Carolina State Highway Department, as the appellant, appealed the district court's decision directly to the U.S. Supreme Court.
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Issue:
Does a state law that imposes uniform, non-discriminatory weight and width limitations on all trucks using its highways violate the Commerce Clause by placing an undue burden on interstate commerce?
Opinions:
Majority - Justice Stone
No, a state law imposing uniform, non-discriminatory weight and width limitations on trucks does not violate the Commerce Clause. State regulation of highways is a matter of peculiarly local concern, and in the absence of federal legislation, states may prescribe uniform regulations for safety and conservation applicable to both interstate and intrastate commerce. The judicial function is not to weigh the wisdom of legislative choices, but to determine whether the legislature has acted within its province and if the means chosen are reasonably adapted to the end sought. As long as the regulation is non-discriminatory and its reasonableness is 'fairly debatable,' the Court will defer to the legislative judgment. Here, South Carolina's regulations had a rational basis, supported by evidence regarding the construction of its highways (many lacking center joints) and safety concerns, and thus the resulting burden on interstate commerce is constitutionally permissible.
Analysis:
This case establishes a strong principle of judicial deference to state legislative judgments regarding highway safety regulations under the dormant Commerce Clause. It affirms that states have broad authority to regulate matters of local concern, like their own roads, even if it substantially affects interstate commerce, provided the regulations are non-discriminatory and have a rational basis. The decision sets a high bar for challenging such laws, requiring a showing that the legislative choice is arbitrary and without a rational basis, rather than merely that a different, less burdensome regulation might exist. This approach contrasts with cases where courts apply a stricter balancing test to state laws that affect national uniformity or discriminate against out-of-state interests.
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