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Raymond Motor Transp., Inc. v. Rice, 434 U.S. 429, 98 S.Ct. 787, 54 L.Ed.2d 664

Facts

Appellants Raymond Motor Transportation, Inc. and Consolidated Freightways Corporation sought permits to operate 65-foot double-trailer trucks on certain interstate highways in Wisconsin. Their applications were denied based on state regulations that generally prohibited vehicles longer than 55 feet without a permit. The appellants presented evidence that 65-foot doubles were as safe as 55-foot singles and that the regulations disrupted their operations, increased costs, and slowed service. The state allowed many exceptions to the 55-foot rule, which the appellants argued undermined the validity of the regulations.

Appellant motor carriers were denied permits to operate 65-foot double-trailer units on certain interstate highways in Wisconsin on the ground that their proposed operations were not within the narrow scope of the regulations specifying when 'trailer train' permits will be issued.

Issue

Do Wisconsin's regulations prohibiting the operation of 65-foot double-trailer trucks on state highways violate the Commerce Clause by imposing an unconstitutional burden on interstate commerce?

We consider on this appeal whether administrative regulations of the State of Wisconsin governing the length and configuration of trucks that may be operated within the State violate the Commerce Clause because they unconstitutionally burden or discriminate against interstate commerce.

Rule

State regulations that impose a burden on interstate commerce must serve a legitimate local interest and not be excessively burdensome in relation to the benefits provided. The presumption of validity for state safety regulations can be overcome if evidence shows that the regulations do not contribute meaningfully to safety.

By its terms, the Commerce Clause grants Congress the power '[t]o regulate Commerce . . . among the several States . . . .'

Analysis

The Supreme Court found that the evidence presented by the appellants overwhelmingly demonstrated that the 65-foot doubles were as safe as 55-foot singles. The state failed to provide any substantial evidence to support its claim that the regulations contributed to highway safety. Furthermore, the numerous exceptions to the 55-foot rule weakened the presumption of validity for the regulations, indicating that they were more about local interests than genuine safety concerns.

Despite the strength of this presumption we are persuaded by the record in this case that the challenged regulations unconstitutionally burden interstate commerce.

Conclusion

The Supreme Court reversed the District Court's ruling, concluding that Wisconsin's regulations unconstitutionally burdened interstate commerce and did not provide a legitimate contribution to highway safety.

On this record, we are persuaded that the challenged regulations violate the Commerce Clause because they place a substantial burden on interstate commerce and they cannot be said to make more than the most speculative contribution to highway safety.

Who won?

The interstate trucking companies prevailed because the Supreme Court found that Wisconsin's regulations placed an undue burden on interstate commerce without sufficient justification related to safety.

The Supreme Court, Mr. Justice Powell, held that: (1) exemptions, such as exceptions under Wisconsin's regulatory scheme to general rule that vehicles over 55 feet long cannot be operated on highways within state, weaken presumption in favor of validity of general limit, because they undermine assumption that state's own political processes will act as a check on local regulations that unduly burden interstate commerce.

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