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Parker v. Brown, 317 U.S. 341, 63 S.Ct. 307, 87 L.Ed. 315

Facts

Porter L. Brown, a raisin producer and packer in California, filed a lawsuit to prevent state officials from enforcing a marketing program for the 1940 raisin crop. The program, established under the California Agricultural Prorate Act, required producers to deliver a significant portion of their crop to a program committee for controlled marketing. Brown argued that the program violated the Sherman Act and the Commerce Clause, as it imposed restrictions on his ability to market his raisins in interstate commerce.

Porter L. Brown, a raisin producer and packer in California, filed a lawsuit to prevent state officials from enforcing a marketing program for the 1940 raisin crop. The program, established under the California Agricultural Prorate Act, required producers to deliver a significant portion of their crop to a program committee for controlled marketing.

Issue

Whether the marketing program for the 1940 raisin crop under the California Agricultural Prorate Act is invalid due to violations of the Sherman Act, the Agricultural Marketing Agreement Act of 1937, or the Commerce Clause of the Constitution.

Whether the marketing program for the 1940 raisin crop under the California Agricultural Prorate Act is invalid due to violations of the Sherman Act, the Agricultural Marketing Agreement Act of 1937, or the Commerce Clause of the Constitution.

Rule

The Sherman Act prohibits contracts, combinations, or conspiracies in restraint of trade or commerce among the several States, while the Agricultural Marketing Agreement Act allows the Secretary of Agriculture to issue orders limiting the quantity of agricultural products marketed in a way that affects interstate commerce.

The Sherman Act prohibits contracts, combinations, or conspiracies in restraint of trade or commerce among the several States, while the Agricultural Marketing Agreement Act allows the Secretary of Agriculture to issue orders limiting the quantity of agricultural products marketed in a way that affects interstate commerce.

Analysis

The court analyzed the California prorate program and determined that it was established by state legislative authority rather than through private agreements or conspiracies. The program was designed to control the marketing of raisins to stabilize prices and prevent economic waste. The court concluded that the Sherman Act does not restrain state action directed by its legislature, and thus the program did not violate the Act. Furthermore, the court found no conflict with the Agricultural Marketing Agreement Act since the Secretary of Agriculture had not issued any order regulating raisins.

The court analyzed the California prorate program and determined that it was established by state legislative authority rather than through private agreements or conspiracies. The program was designed to control the marketing of raisins to stabilize prices and prevent economic waste.

Conclusion

The court reversed the lower court's decision, holding that the California Agricultural Prorate Act's marketing program for raisins did not violate the Sherman Act or the Commerce Clause.

The court reversed the lower court's decision, holding that the California Agricultural Prorate Act's marketing program for raisins did not violate the Sherman Act or the Commerce Clause.

Who won?

The defendants prevailed in the case because the court found that the California prorate program was a legitimate exercise of state authority and did not violate federal laws.

The defendants prevailed in the case because the court found that the California prorate program was a legitimate exercise of state authority and did not violate federal laws.

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