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Keywords

injunctioncompliancesolid waste
jurisdictionsolid waste

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C & A Carbone, Inc. v. Town of Clarkstown, N.Y., 511 U.S. 383, 114 S.Ct. 1677, 128 L.Ed.2d 399, 38 ERC 1529, 62 USLW 4315, 24 Envtl. L. Rep. 20,815

Facts

The Town of Clarkstown entered into a consent decree to close its landfill and build a solid waste transfer station, guaranteeing a minimum waste flow to the facility. To enforce this, the town adopted a flow control ordinance requiring all nonhazardous solid waste to be deposited at the transfer station. Carbone, a local recycling company, was found to be shipping nonrecyclable waste out of state, leading the town to seek an injunction to enforce compliance with the ordinance. The lower court upheld the ordinance as constitutional, but this decision was challenged.

The Town of Clarkstown entered into a consent decree to close its landfill and build a solid waste transfer station, guaranteeing a minimum waste flow to the facility.

Issue

Does the flow control ordinance enacted by the Town of Clarkstown violate the Commerce Clause by discriminating against interstate commerce?

Does the flow control ordinance enacted by the Town of Clarkstown violate the Commerce Clause by discriminating against interstate commerce?

Rule

The Commerce Clause prohibits state and local laws that discriminate against interstate commerce, particularly those that favor local businesses over out-of-state competitors.

The Commerce Clause prohibits state and local laws that discriminate against interstate commerce, particularly those that favor local businesses over out-of-state competitors.

Analysis

The court determined that the flow control ordinance regulated interstate commerce by imposing additional costs on out-of-state businesses and restricting their access to the local market. The ordinance was found to discriminate against interstate commerce by allowing only a favored local operator to process waste, thus limiting competition and investment from out-of-state firms. The court concluded that the ordinance's economic effects were significant enough to bring it under the scrutiny of the Commerce Clause.

The ordinance regulates interstate commerce. While its immediate effect is to direct local transport of solid waste to a designated site within the local jurisdiction, its economic effects are interstate in reach.

Conclusion

The Supreme Court reversed the lower court's decision, holding that the flow control ordinance violated the Commerce Clause and remanded the case for further proceedings.

We reverse the judgment and remand the case for proceedings not inconsistent with this decision.

Who won?

C. & A. Carbone, Inc. prevailed in the case as the Supreme Court found the flow control ordinance unconstitutional for discriminating against interstate commerce.

C. & A. Carbone, Inc. prevailed in the case as the Supreme Court found the flow control ordinance unconstitutional for discriminating against interstate commerce.

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