South-Western Legal Studies in Business

State Restriction on Out-of-State Wine Shipments Unconstitutional
Description Federal appeals court held that a Michigan statute that prohibited out-of-state wine sellers from shipping wine to customers in Michigan but allowed in-state wine sellers to ship wine, was a violation of the Commerce Clause.
Topic Constitutional Law
Key Words Commerce Clause; Wine Shipments
C A S E   S U M M A R Y
Facts Michigan prohibited out-of-state wineries from shipping wine to Michigan residents. It allowed wine sellers in Michigan to ship wine to Michigan residents. The state was sued by a California winery and by wine consumers in Michigan for an unconstitutional restriction on the free flow of interstate commerce. The state defended that it has the right to regulate alcoholic beverages under the Twenty-first Amendment to the Constitution. The district court held in favor of the state; plaintiffs appealed.

Reversed and remanded. The Michigan scheme violates the Commerce Clause. It gives in-state wineries a competitive advantage over out-of-state wineries. There is no showing that the scheme furthers a legitimate state interest under the Twenty-first Amendment that could not be adequately served by reasonable nondiscriminatory alternatives.

Citation Heald v. Engler, 342 F.3d 517 (6th Cir., 2003)

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