Florida Lime & Avocado Growers, Inc. v. Paul (1962)
- Docket
- 45
- Decided
- 1962-01-01
- Category
- General
Summary
Question: Was the California law prohibiting the sale or transportation of certain avocados within its borders constitutionally valid? Conclusion: Preemption does not arise if there is no direct conflict between federal and state laws, meaning that it is possible to comply with both of them simultaneously, and if the state law does not frustrate the purpose of the federal law. In an opinion authored by Justice William Brennan, the Court held that federal law will preempt a state law if it is physically impossible to comply with both laws. In this situation, it would be possible to comply with both laws, since the Florida growers could have met the California standard if they had allowed their avocados more time to grow. This means that there was no inherent conflict between the two laws. Justices White, Black, Douglas, and Clark dissented on the ground that the California statute was invalid under the Supremacy Clause of the Federal Constitution.