Hughes v. Alexandria Scrap Corp.

426 U.S. 794 (1976)

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Hughes v. Alexandria Scrap Corp.

United States Supreme Court
426 U.S. 794 (1976)

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Facts

In 1969, the State of Maryland (the state) (defendant) enacted a statute that sought to rid the state of abandoned automobiles (known as “hulks”). Specifically, the statute was designed to accelerate the process by which vehicle suppliers sold hulks to scrap processors so that the processors could recycle the hulks into scrap metal. Under the statute, the state provided financial rewards (or “bounties”) to scrap processors that recycled hulks registered in Maryland. The bounties incentivized vehicle suppliers to sell hulks to scrap processors by allowing the processors to pay higher than normal prices for the hulks. Moreover, bounties were provided to both in-state and out-of-state scrap processors, so long as the scrap processors supplied documentation indicating that the hulks were registered in Maryland. However, in 1974, the state amended the statute, requiring more extensive documentation from out-of-state scrap processors than those located in Maryland. Out-of-state scrap processors, in turn, demanded more extensive documentation from vehicle suppliers. Hence, because of the 1974 amendment, it was easier for vehicle suppliers to sell hulks to in-state scrap processors, causing a decline in the number of hulks sold to out-of-state scrap processors. Alexandria Scrap Corporation (Alexandria) (plaintiff), a scrap processor located in Virginia, brought suit against the state, contending that the 1974 amendment burdened interstate commerce in violation of the Commerce Clause of the United States Constitution. The district court granted summary judgment in favor of Alexandria. The state appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Powell, J.)

Concurrence (Stevens, J.)

Dissent (Brennan, J.)

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