United Haulers Ass'n v. Oneida-Herkimer Solid Waste Management Authority

The Second Circuit Court of Appeals reversed, reasoning that the public benefit outweighed any restriction on interstate commerce.

Chief Justice Roberts, writing for the Court, held that the law did not violate the dormant commerce clause.

In Carbone v. Clarkstown,[1] the Court struck down a similar flow control ordinance that forced haulers to deliver waste to a private processing facility.

Here, the Court held that because the facilities were owned and operated by a state-created public benefit corporation, the restriction was permissible.

Justice Scalia agreed with the Court's holding, and wrote separately to restate his opinion that "the so-called 'negative' Commerce Clause is an unjustified judicial invention, not to be expanded beyond its existing domain."