No, this law is fair and constitutional. The government doesn't have to prove its solution to a problem is perfect; it just needs a 'rational basis'—a reasonable argument—for its choice. Minnesota had several reasonable arguments: 1) Banning new plastic jugs might encourage better, reusable containers in the future. 2) Banning plastic jugs before every dairy switched to them would cause less chaos for businesses. 3) They could have believed it saved energy since plastic comes from oil. 4) They could have believed it reduced landfill trash. Since these ideas aren't crazy, the law is okay. It also doesn't illegally block trade between states because it treats all sellers, from Minnesota or not, the same.

Yes, this law is unfair, and we should trust Minnesota's top court. The big mistake here is the U.S. Supreme Court telling Minnesota's courts how to do their job. It's up to Minnesota to decide how much its courts can question the state legislature. Minnesota's own highest court looked at the facts and decided the law was irrational. We should have respected that decision instead of doing our own investigation and overruling them. The Court also shouldn't have made a ruling on the interstate trade issue, because the Minnesota court never even got to that question.

The law is probably fair, but the Court shouldn't have decided the whole case. I agree that the law doesn't violate the 'equal protection' rule because the state had a rational basis. However, I think the Court should not have made a decision about whether the law hurts businesses in other states. The first court to hear the case found that the real reason for the law was to help Minnesota's paper industry, not the environment. We should have sent the case back to Minnesota's top court to decide that specific issue.

Yes, the law is okay. The people who make laws in Minnesota were allowed to think that stopping stores from selling milk in plastic containers might help the environment. The law treats businesses from other states fairly too. It doesn't cause them too many problems. And some businesses in Minnesota are affected by the law as well, which shows it's not just about hurting businesses from outside the state.

The Supreme Court shouldn't change what the Minnesota courts decided. The Minnesota courts used the right rules and tests when looking at this law. They did their job in deciding if the law was okay based on the state's constitution. The Supreme Court is changing the decision because they don't like how the Minnesota courts see their role, not because the Minnesota courts used the wrong federal rules.

I agree the law is okay under equal protection, but I wouldn't decide the Commerce Clause issue. The trial court found the real reason for the law was to help local businesses, which matters for figuring out if it discriminates against interstate commerce. The Minnesota Supreme Court didn't disagree with these findings. The case should be sent back to consider if the law improperly discriminated against interstate commerce.

"The fact that the burden of a state regulation falls on some interstate companies does not, by itself, establish a claim of discrimination against interstate commerce."

—the State of Minnesota banned retail sale of milk in plastic nonreturnable, nonrefillable containers, but permitted such sale in other nonreturnable, nonrefillable containers, such as paperboard milk cartons.

That would be a rational basis for the statute and would be sufficient for the statute to withstand an equal protection challenge.

Instead, the statute survives if the legislature "could rationally have decided" that it would fulfill its purpose.

—the Supreme Court considered whether a Minnesota statute banning the retail sale of milk in plastic non-returnable, non-refillable containers violated the Clause.

Whether in fact the Act will promote more environmentally desirable milk packaging is not the questions: the Equal Protection Clause is satisfied by our conclusion that the Minnesota Legislature could rationally have decided that its ban... might foster greater use of environmentally desirable alternatives

The Court stated that "[o] nly if the burden on interstate commerce clearly outweighs the State's legitimate purposes does such a regulation violate the Commerce Clause."

—the legislative facts on which the classification is apparently based rationally may have been considered to be true by the governmental decisionmaker

There is no narrow tailoring requirement under the Twenty-first Amendment, and the residency requirement is not invalid because the legislature might have gone further than it did.

—t] he existence of major in-state interests adversely affected by the [state statute] is a powerful safeguard against legislative abuse

No. The Minnesota statute does not violate the Equal Protection Clause or the Commerce Clause. Under the rational basis test, a legislative classification must be sustained if it is rationally related to a legitimate state purpose, and courts may not substitute their judgment for the legislature's on debatable factual questions. The Minnesota Legislature could have rationally concluded that the ban would promote environmental goals by: 1) encouraging the development of environmentally superior alternatives before the plastic jug became entrenched; 2) minimizing economic dislocation by banning the newer container type before the industry became heavily reliant on it; 3) conserving energy, since plastic is a petroleum byproduct and paperboard is made from a renewable resource; and 4) easing solid waste disposal, based on evidence suggesting plastic containers take up more landfill space. Because these points are at least debatable, the classification survives rational basis review. Furthermore, the statute does not violate the Commerce Clause because it regulates evenhandedly, and its incidental burden on interstate commerce is not clearly excessive compared to the substantial local benefits in environmental protection and resource conservation.

Yes. The judgment of the Minnesota Supreme Court should be affirmed. The majority errs by creating a new federal constitutional principle that limits the power of state courts to review the factual basis of their own state legislature's actions. The allocation of functions between a state's legislature and its judiciary is a matter of state law, not federal constitutional law. This Court should have deferred to the Minnesota Supreme Court's finding, as a matter of state process, that the statute was not rationally related to its stated environmental objectives. The U.S. Supreme Court has no precedent for conducting its own de novo review of a state legislative record to find a rational basis that the state's highest court has expressly rejected. The majority also improperly decided the Commerce Clause issue, which the Minnesota Supreme Court had explicitly declined to address.

No as to Equal Protection; the Commerce Clause issue should not be decided. The statute survives an equal protection challenge under the rational basis test. However, this Court should not have reached the Commerce Clause issue. The trial court made an explicit factual finding that the statute's 'actual basis was to promote the economic interests of certain segments of the local dairy and pulpwood industries.' The Minnesota Supreme Court did not reject this finding; it merely found the statute unconstitutional on other grounds and did not address the Commerce Clause. This Court should have remanded the case for the Minnesota Supreme Court to consider the Commerce Clause claim in light of the trial court's finding of discriminatory purpose.

Yes. The Minnesota statute does not violate the Equal Protection Clause because the legislature could rationally have decided that its ban on plastic nonreturnable milk jugs might foster greater use of environmentally desirable alternatives. The statute also does not violate the Commerce Clause as it regulates evenhandedly to effectuate a legitimate local public interest, and the burden imposed on interstate commerce is not clearly excessive in relation to the putative local benefits. The existence of major in-state interests adversely affected by the statute is a safeguard against legislative abuse.

The Court's reversal of the Minnesota Supreme Court is based upon a newly discovered principle of federal constitutional law that defines the relationship between state legislatures and state courts. I can find no support for this novel constitutional doctrine. The Minnesota Supreme Court applied the proper federal equal protection standard and properly declined to consider the Commerce Clause. The majority reverses this decision because it disagrees with the Minnesota courts' perception of their role in the State's lawmaking process, not because of any error in the application of federal law.

I concur that the statute survives equal protection challenge, but would not reach the Commerce Clause issue. The District Court expressly found that the actual basis of the statute was to promote local economic interests, which is highly relevant to whether the statute discriminated against interstate commerce. The Minnesota Supreme Court did not reject these findings. This Court has no basis for inferring a rejection of the specific factfindings by the trial court. I would remand the case with instructions to consider specifically whether the statute discriminated impermissibly against interstate commerce.

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