South Carolina State Highway Dept. v. Barnwell Bros., Inc. – Case Brief
Summary of South Carolina State Highway Department v. Barnwell Brothers, Inc., 303 U.S. 177, 58 S. Ct. 510, 82 L. Ed. 734 (1938).
South Carolina passed a law in 1933 that prohibited trucks with gross vehicle weight exceeding 20,000 pounds and width exceeding 90 inches from using state highways. Barnwell Brothers, Inc. (P) and other truckers and interstate shippers brought suit in federal district court against the South Carolina State Highway Department (D) to enjoin enforcement of the law on the grounds that it violated the Due Process Clause of the Fourteenth Amendment, and imposed an unconstitutional burden on interstate commerce in violation of the Commerce Clause.
The district court ruled in favor of the plaintiffs, holding that the law imposed an unreasonable burden on interstate commerce because it prohibited a large portion of traffic from passing through the state. Statistical evidence showed that 90% of trucks had widths of 96 inches and only four other states limited weight to less than 20,000 pounds.
Under what circumstances will a state highway regulation be valid in light of the Commerce Clause?
Holding and Rule (Stone)
A state highway regulation is valid provided that it discriminates equally between interstate and intrastate commerce and there is a rational basis for the law.
In the absence of federal legislation, a state may adopt regulations limiting the weight and width of vehicles in order to promote safety and conserve its highways, provided such regulations do not discriminate between vehicles traveling in interstate commerce and vehicles traveling only within the state. The states generally have the power to regulate in such matters, and judicial inquiry into the validity of such regulations in light of the Commerce Clause and the Fourteenth Amendment is limited to the issue of whether the restrictions are reasonably adapted to the end sought (i.e. the rational basis test).
The adoption of one weight or width regulation versus another is a legislative not a judicial choice. It is not to be determined by a court weighing the merits of the legislative choice and rejecting it if the evidence appears to favor a different standard.
The record fails to exclude the possibility that there exists a rational basis for the regulations and indeed shows that there is adequate support for the legislative judgment. These measures as adopted are within the legislative power of South Carolina.
See Wickard v. Filburn for a constitutional law case brief holding that the Commerce Clause grants Congress the power to regulate local activities that have an aggregate effect on interstate commerce.