Bibb v. Navajo Freight Lines Inc. (1958)

Docket
94
Decided
1958-01-01
Category
General

Summary

Question: Did a law which required a specific type of rear mudguard on trucks and trailers operated on Illinois's state highways violate the Commerce Clause of the Constitution? Conclusion: In a unanimous opinion authored by William O. Douglas, the Court held that the Illinois requirement placed an unconstitutional burden on interstate commerce. While writing that safety measures "carry a strong presumption of validity when challenged," Justice Douglas nevertheless affirmed that if the effect of such measures are "slight or problematical," then the interests of commerce should prevail. No clear benefits of using contoured mudguards could be identified, and they might even lead to additional hazards. Thus, the presumption of validity could be overcome. Justices Harlan and Stewart concurred.

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