1. Facts
1.1. Parties
1.1.1. Family Winemakers of CA
1.1.2. Eddie J. Jenkins
1.2. What Happened
1.2.1. In 2006, MA legislature makes distinctions between:
1.2.1.1. Small Winery (less than 30,000 gallons)
1.2.1.2. Large Winery (more than 30,000 gallons)
1.2.2. Large Wineries can choose only one of the following options:
1.2.2.1. Remain within 3-tier system and distribute wines solely through wholesalers
1.2.2.2. Sell wines in MA exclusively through direct shipping
1.2.3. Small Wineries can simultaneously utilize both options, whereas large wineries can only choose one
1.3. Procedural History
1.3.1. First Circuit Court affirmed judgement of district court
1.3.1.1. 2006 law altered the competitive balance to:
1.3.1.1.1. Favor MA wineries
1.3.1.1.2. Disfavor out-of-state competition
2. Issue
2.1. Does the 2006 law give a competitive advantage to MA over other states? Or is there no advantage to be had by MA over other states?
3. Rule of Law
3.1. Discrimination under the Commerce Clause is occuring
4. Application
4.1. Plaintiffs claimed 30,000 gallons as a demarcation held a discriminatory:
4.1.1. Effect
4.1.1.1. Definition of large wineries encompasses wineries that produce 98% of all wine in US
4.1.1.1.1. All of which are located outside of MA
4.1.1.2. All wines produced in MA are from small wineries that can use multiple distribution channels
4.1.2. Purpose
4.2. MA claimed there can be no discrimination because MA small wineries are made no better off than their out-of-state counterparts
4.2.1. Gallonage cap ensures MA's wineries obtain advantages over out-of-state wineries
5. Conclusion
5.1. First Circuit Court affirmed judgement of the district court
6. Impact
6.1. DIRECT TV Inc. and Echostar Satellite LLC v. Joseph Testa, Tax Commissioner of Ohio
6.1.1. Plaintiffs argue that protectionist state favors business that showers the state with economic benefits (Commerce Clause violation)
6.1.2. Ohio Supreme Court disputed what qualifies as discrimination against interstate commerce. Commissioner of Ohio believes the advantage of cable over satellite is irrelevant to a Commerce Clause violation.
6.1.3. Conclusion: Courts found plaintiff's argument irrelevant to federal structure and recommended denial of petition
6.2. Black Star Farms LLC v. Oliver
6.2.1. Arizona's wine distribution laws disadvantage out-of-state wineries, favor in-state wineries, and protect the economic interest of the Arizona wine industry
6.2.2. Arizona argued that it was not discriminatory because plaintiffs had not proven that the law gave in-state wine a larger market share
6.2.3. Conclusion: Arizona's statutory scheme was found to declare the 50,000 gallon production limits to be unconstitutional