Module 2 Case

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Module 2 Case by Mind Map: Module 2 Case

1. Family Winemakers of California v. Jenkins

1.1. Facts

1.1.1. Parties

1.1.1.1. FAMILY WINEMAKERS OF CALIFORNIA, Stephen J. Poor, III, M.D., Gerald C. Leader, Plaintiffs, Appellees

1.1.1.2. Eddie J. JENKINS, in his official capacity as Chairman of the Massachusetts Alcoholic Beverages Control Commission;  Robert H. Cronin and Susan Corcoran, in their official capacities as Associate Commissioners of the Massachusetts Alcoholic Beverages Control Commission, Defendants, Appellants

1.1.2. What Happened

1.1.2.1. California winemakers challenged a Massachusetts law requiring out of state winemakers that produce more than 30,000 gallons a year to choose between either  direct shipping to consumers or selling only through state wholesalers.

1.1.2.2. Massachusetts's winemakers were not affected by the law, due to the intentional modifications of the law by the state to prevent damage to its state producers

1.1.3. Procedural History

1.1.3.1. 2008 Trial court decided that the law was unconstitutional due to being restriction on interstate commerce

1.1.3.1.1. The judge suggested the state was practicing economic protectionism

1.1.3.2. Massachusetts appealed to the U.S. Court of Appeals for the First Circuit

1.2. Issue Before the Court

1.2.1. Court to resolve if the Massachusetts law unconstitutionally discriminates against interstate commerce while considering the Commerce Clause and the 21st Ammendment

1.3. Rule

1.3.1. "Dormant" Commerce Clause of the Constitution prevents states from making regulationsthat interfere with interstate commerce

1.3.2. 21st Amendment of the Constitution gives states rights to regulate alcohol

1.4. Application

1.4.1. Massachusetts claimed that the California winemakers had not shown that the law selectively benefited MA wineries and selectively harmed out of state wineries.

1.4.2. California winemakers claimed that the MA law was intended to protect MA wineries while simultaneously harming out-of-state wineries

1.4.2.1. The judge agreed with the California winemakers

1.4.2.1.1. The court minimized the 21st Amendment's power, suggested there were alternatives that MA could use that were not discriminatory on interstate commerce, and reiterated the importance of the Commerce Clause

1.5. Conclusion

1.5.1. Appeallate court upheld the lower court ruling that the Massachusetts law violated the Commerce Clause of the Constitution.

1.6. Impact of the Decision

1.6.1. The 21st Amendment was weakened

1.6.1.1. States will be required to provide more proof that laws restricting interstate alcohol commerce are not discriminatory

1.6.1.2. The possibility for challenges based on the ruling will make states hesitant to restrict interstate alcohol sales

1.6.2. Outcome of this case threatned the legitimacy of a Florida legislature 250,000 gallon cap

1.7. What would a Business Professional Care?

1.7.1. Midsize to large winemakers that want to sell their products directly to consumers in other states would want to utilize this precedent

1.8. Current Business Practices Influenced by the Holding

1.8.1. California winemakers are now able to sell direct to consumers in over 40 states

1.8.2. California Family Winemakers have converted to a large wine advocacy and lobbying group that is tasked with combating state laws, taxes, and regulations that inhibit the wine industry.

1.8.3. The states have a larger evidentiary burden now to support possibly discriminatory laws. This gives many businesses a foothold when combating interstate trade restrictions.