Family Wine Makers of  California v. Jenkins

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Family Wine Makers of  California v. Jenkins by Mind Map: Family Wine Makers of  California v. Jenkins

1. Application

1.1. Plaintiffs must prove that the law provides preferential treatment to "small" wineries

1.1.1. Evidence put forth by the Plaintiffs demonstrates that the law placed preferential treatment of "small" wineries and was found to be discriminatory in nature

1.1.1.1. A clear advantage was created in the 2006 MA law due to the fact that 98% of the US production of wine falls outside of MA

1.1.1.2. All wineries within MA produce <30k gallons

2. Rule of Law

2.1. Dormant Commerce Clause

2.1.1. Discrimination defined as "differential treatment of in-state and out-of-state economic interests that benefits the former and burdens the latter"

2.1.1.1. State laws that favor in-state interests over out-of-state competitors have long been subject to invalidation

3. Conclusion

3.1. The 2006 MA law altered the competitive balance in favor of MA wineries and disfavor out-of-state competition by design

4. Facts

4.1. Massachusetts (MA) had a 3-tier system to control the sale of alcoholic beverages within their territory. The distinction is made between producers, wholesalers, and retailers

4.1.1. Producers can sell alcoholic beverages to licensed in-state wholesalers

4.1.2. Wholesalers obtain licenses to sell to retailers

4.1.3. Retailers obtain a licence to sell to consumers or to serve alcohol on the premises

4.2. Before 2005 MA's licensing law allowed only in state wineries to obtain licenses to combine distribution methods through wholesalers, retailers, and direct shipping to consumers

4.2.1. The US supreme court invalidated this law under the Commerce Clause being that it was discriminatory in nature

4.3. In 2006, MA enacted a law that distinguishes "small" or "large" wineries based on a 30k gallon production cap

4.3.1. This was in contrast to the previously invalidated law of in-state vs out-of-state tier system

4.3.2. "Large" Wineries: Allowed to choose between the 3-tier system OR sell their wines exclusively in MA through direct shipping

4.3.3. "Small" Wineries: Allowed to be part of the 3-tier system AND sell direct

5. Impact of the Decision #1

5.1. ○ COORS BREWING COMPANY, Plaintiff, v. JUAN CARLOS MÉNDEZ-TORRES

5.1.1. Plaintiff alleged that Defendant enacted discriminatory tax practices against large brewery Coors that was not enacted against small breweries

5.2. Court decided against Coors

6. Impact of the Decision #2

6.1. DIRECTV, INC., N/K/A DIRECTV, LLC, AND ECHOSTAR SATELLITE, L.L.C., N/K/A DISH NETWORK, L.L.C., Appellants, v. STATE OF FLORIDA

6.1.1. The dormant Commerce Clause does not protect satellite TV providers from differential tax treatment simply because their technology is not land based (ie cable)

7. Why a business professional would care about the Commerce Clause

7.1. A professional would care about this law because it protects against discriminatory practices that would disadvantage a company