Home › Case briefs › Constitutional Law

Hunt v. Washington State Apple Advertising Commission

Supreme Court of the United States · 1977 · Constitutional Law

Constitutional LawCommerce ClauseStandingFederal JurisdictionCommerce Clausedormant commerce clauseassociational standingrepresentational standing

Facts

Washington required apples shipped in interstate commerce to undergo a strict state inspection and grading program, and Washington grades had gained substantial acceptance in the trade as equivalent or superior to USDA grades. North Carolina enacted a law requiring all closed containers of apples sold, offered for sale, or shipped into the State to bear no grade other than the applicable USDA grade or certain non-grade markings, thereby prohibiting display of Washington State grades. Because Washington growers used preprinted containers and stored apples before their eventual destination was known, compliance required relabeling, repacking, changing storage and marketing practices, or abandoning the North Carolina market. The Commission, a state agency funded and controlled by Washington apple growers and dealers, sought declaratory and injunctive relief after unsuccessful attempts to obtain an administrative exemption.

Issue

Whether the Commission had standing and satisfied the amount-in-controversy requirement under 28 U.S.C. § 1331, and whether North Carolina's statute violated the Commerce Clause by prohibiting the display of Washington State apple grades on closed containers shipped into the State. More specifically, the Commerce Clause question was whether a facially neutral grading law that burdened and disadvantaged Washington apples could be justified by North Carolina's asserted interest in preventing consumer confusion and deception.

Rule

An association has standing to sue on behalf of its constituents when: (a) its members would otherwise have standing to sue in their own right; (b) the interests it seeks to protect are germane to the organization's purpose; and (c) neither the claim asserted nor the relief requested requires the participation of individual members in the lawsuit. When state legislation is shown to discriminate against interstate commerce, the State bears the burden of justifying it in terms of the local benefits flowing from the statute and the unavailability of adequate nondiscriminatory alternatives. In actions for declaratory or injunctive relief, the amount in controversy is measured by the value of the object of the litigation, including losses and compliance costs caused by the challenged law.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Oregon created the Berry Growers Promotion Board to protect and promote the state's blueberry industry. The board is funded entirely by mandatory assessments on blueberry growers, only growers may vote for board members, and only growers may serve on the board. When Nevada bars packaged berries from displaying Oregon quality grades, the board sues for declaratory and injunctive relief on behalf of Oregon growers.

Does the board most likely have standing to sue in a representational capacity?

Explanation. An association may sue on behalf of its constituents when the constituents would have standing themselves, the interests are germane to the organization's purpose, and neither the claim nor the requested relief requires individual participation. The majority treated a state agency as equivalent to a trade association where the affected producers elected it, financed it, and were its primary beneficiaries. Mandatory rather than voluntary participation did not defeat representational standing.