Granholm v. Heald (2005)
Facts
Once the 21st Amendment passed, granting states the power to regulate the sale of alcohol, nearly half the states began requiring out-of-state wineries to go through licensed wholesalers within the state to sell their products. Wineries adversely affected by this statute challenged laws in New York and Michigan allowing wineries to directly ship to consumers from in-state wineries but not from out-of-state wineries. In Michigan, the U.S. District Court for the Eastern District of Michigan upheld the state’s regulations while the U.S. Court of Appeals for the Sixth Circuit reversed. In New York, the U.S. District Court for the Southern District of New York invalidated the state regulation while the U.S. Court of Appeals for the Second Circuit reversed.
Issue
Did the New York and Michigan laws against interstate commerce violate the Commerce Clause of Article I?
Rule…show more content… Article I, section 8, clause 3, the Commerce Clause, grants Congress the power to regulate commerce with foreign nations and among the states.
Application
Justice Kennedy argued Michigan and New York were treating in-state and out-of-state wineries differently, which classified as discrimination against interstate commerce under the Commerce Clause. The regulation of alcohol in the states followed a three-tier distribution system, which only applied to sales from out-of-state wineries. This differential treatment violated the Commerce Clause because it benefited Michigan and New York and harmed the out-of-state wineries. States could not enact laws harming businesses outside of the state in order to compete with them. New York and Michigan asserted section 2 of the 21st
