Minnesota v. Clover Leaf Creamery Co.

Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456 (1981), was a United States Supreme Court case which found no violation of the equal protection or commerce clauses in a Minnesota state statute banning retail sale of milk in plastic nonreturnable, nonrefillable containers, but permitting such sale in other nonreturnable, nonrefillable containers.

The Supreme Court of Minnesota affirmed on the federal equal protection and due process grounds, without reaching the commerce clause or state law issues, holding that the discrimination against plastic nonrefillables was not rationally related to the statute's stated objectives of promoting resource conservation, easing solid waste disposal problems, and conserving energy (289 NW2d 79).

The controversy centered on the narrow issue of whether the legislative classification between plastic and nonplastic, nonreturnable milk containers was rationally related to achievement of conservation.

The controlling question was whether the incidental burden imposed on interstate commerce by §116F.21 was clearly excessive in relation to the local benefits.

It was held that (1) the ban on plastic nonreturnable milk containers was rationally related to the achievement of legitimate state purposes and thus did not violate the equal protection or due process clauses of the Fourteenth Amendment, since the state legislature could rationally have decided that its ban on plastic nonreturnable milk jugs might foster greater use of environmentally desirable alternatives, even though another type of nonreturnable is permitted to continue in use, having concluded that nonreturnable, nonrefillable milk containers pose environmental hazards, it was not arbitrary or irrational to ban the most recent entry into the field while in effect "grandfathering" paperboard containers, and the legislature had concluded, on evidence sufficient to make the questions at least debatable, that the statute would help to conserve energy and ease the state's solid waste disposal problem, and (2) the statute did not violate the commerce clause, since it regulated even-handedly by prohibiting all milk retailers from selling their products in plastic, nonreturnable milk containers, without regard to whether the milk, the containers, or the sellers are from out of state, the burden imposed on interstate commerce was relatively minor and was not clearly excessive in light of the substantial state interest in promoting conservation of energy and other natural resources and easing solid waste disposal problems, and no approach with a lesser impact on interstate activities was available.