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Voight v. Wright, 141 U.S. 62, 11 S.Ct. 855, 35 L.Ed. 638

Facts

In 1886, E. T. Wright, the flour inspector for Norfolk, sued R. P. Voight & Co. for $15 in inspection fees for 750 barrels of flour that the defendants had brought into Virginia from other states. The law in question mandated that all flour offered for sale in Virginia must be inspected, but it did not require inspection for flour manufactured within the state. The defendants argued that the Virginia law conflicted with the U.S. Constitution's commerce clause, leading to the appeal after the corporation court affirmed the initial judgment in favor of Wright.

The plaintiff is the flour inspector for the city of Norfolk, duly appointed and commissioned as such. The defendants are wholesale grocery merchants, conducting their business in the said city.

Issue

The main legal issue was whether the Virginia law requiring inspection of flour brought from other states was constitutional or if it violated the commerce clause of the U.S. Constitution.

The question in the case has respect to the constitutionality of a law of Virginia, passed in March, 1867, by which it was declared as follows: ‘(4) All flour brought into this state and offered for sale therein shall be reviewed, and have the Virginia inspection marked thereon.'

Rule

The court applied the principle that state laws cannot discriminate against out-of-state products in favor of in-state products, as this would impose a burden on interstate commerce.

But it may not, under the guise of exerting its police powers, or of enacting inspection laws, make discriminations against the products and industries of some of the states in favor of the products and industries of its own or of other states.

Analysis

The court found that the Virginia law was discriminatory because it required inspection for flour imported from other states while not imposing the same requirement on flour produced within Virginia. This created an unequal playing field for out-of-state producers, which the court determined was a violation of the commerce clause.

The law in question is a discriminating law, and requires the inspection of flour brought from other states, when such inspection is not required for flour manufactured in Virginia.

Conclusion

The court reversed the judgment of the corporation court of Norfolk, ruling that the Virginia inspection law was unconstitutional and remanding the case for further proceedings consistent with this opinion.

The judgment of the corporation court of the city of Norfolk is reversed, and the cause remanded for further proceedings not inconsistent with this opinion.

Who won?

The prevailing party was R. P. Voight & Co., as the court ruled in their favor by declaring the Virginia law unconstitutional.

The law in question was held to be unconstitutional and void.

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