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Fort Gratiot Sanitary Landfill, Inc. v. Michigan Department of Natural Resources

504 U.S. 353, 112 S. Ct. 2019, 119 L. Ed. 2d 139 (1992)

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Fort Gratiot Sanitary Landfill, Inc. v. Michigan Department of Natural Resources

United States Supreme Court

504 U.S. 353, 112 S. Ct. 2019, 119 L. Ed. 2d 139 (1992)

Facts

The Solid Waste Management Act (SWMA) prohibited any county from accepting the disposal of solid waste that was not generated within that county unless the county’s solid-waste management plan explicitly authorized it. In February 1989, Fort Gratiot Sanitary Landfill, Inc. (landfill) (plaintiff) applied to St. Clair County (county) for the authority to accept up to 1,750 tons of out-of-state solid waste per day. However, the county’s management plan did not authorize the acceptance of out-of-state solid waste. The landfill sued the Michigan Department of Natural Resources (Michigan) (defendant), alleging that the SWMA violated the Commerce Clause of the United States Constitution. Michigan argued that the SWMA did not discriminate against interstate commerce because it treated out-of-county waste in the same manner as out-of-state waste and argued that the SWMA was not clearly excessive relative to the local benefit. Michigan also argued that the SWMA was a health and safety regulation that was necessary to enable individual counties to create adequate plans for the safe disposal of waste. The landfill sought a judgment declaring the SWMA unconstitutional and enjoining its enforcement.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

Dissent (Rehnquist, C.J.)

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