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Constitutional Law Keyed to Choper
Minnesota v. Clover Leaf Creamery Co.
Citation:
449 U.S. 456 (1981)Facts
The Minnesota Legislature enacted a statute in 1977 banning the retail sale of milk in plastic nonreturnable, nonrefillable containers, while permitting such sale in other nonreturnable containers like paperboard cartons. The stated purpose was to promote resource conservation, ease solid waste disposal problems, and conserve energy. The statute was supported by several state agencies. Proponents argued it would prevent the entrenchment of environmentally harmful plastic containers in the market, while opponents contended it would increase costs and prolong the use of paperboard cartons, which they claimed were more environmentally harmful. After the statute passed, respondents filed suit seeking to enjoin its enforcement. The Minnesota District Court found the evidence “in sharp conflict” but resolved it in favor of respondents, concluding the law would not achieve its stated environmental goals and was actually intended to promote local economic interests. The Minnesota Supreme Court affirmed on equal protection grounds, finding the discrimination against plastic nonrefillables was not rationally related to the Act’s objectives.
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