Bibb v. Navajo Freight Lines, Inc.

359 U.S. 520, 79 S. Ct. 962, 3 L. Ed. 2d 1003, 1959 U.S. LEXIS 1777
Supreme Court of the United States·Decided May 25, 1959·No. 94·Published·Cited by 369 cases

Opinions

Mr. Justice Douglas

delivered the opinion of the Court.

We are asked in this case to hold that an Illinois statute1 requiring the use of a certain type of rear fender [522] mudguard on trucks and', trailers operated on the highways of that State conflicts with the Commerce Clause of the Constitution. The statutory specification for this type of mudguard provides that the guard shall contour the rear wheel, with the inside surface being relatively parallel to the top 90 degrees of the rear 180 degrees of the whole surface.2 The surface, of the guard must extend downward to within 10 inches from the ground when the truck is loaded to its maximum legal capacity. The guards must be wide enough to cover the width of the protected tire, must be installed not’ more than 6 inches from the tire surface when the vehicle is loaded [523] to maximum capacity, and must have a lip or flaiige on its outer edge of not less than 2 inches.3

Appellees, interstate motor carriers holding certificates from the Interstate Commerce. Commission, challenged the constitutionality of the Illinois Act. A specially constituted three-judge District Court concluded that it unduly and unreasonably burdened and obstructed interstate commerce, because it made the conventional or straight mudflap, which is legal in at least 45 States,, illegal in Illinois, and because the statute, taken together with a Rule of the Arkansas Commerce Commission4 requiring straight mudflaps, rendered the use of the same motor vehicle equipment in both States impossible. The statute was declared to be violative of the Commerce Clause' and appellants were enjoined from enforcing it. 159 F. Supp. 385. An appeal was taken, and we noted probable jurisdiction. 358 U. S. 808.

The power of the State to regulate the use of its highways is broad and pervasive. We have recognized the peculiarly local nature of this subject of safety, and have upheld state statutes applicable alike to interstate and intrastate commerce, despite the fact that they may have an impact on interstate commerce. South Carolina Highway Dept. v. Barnwell Bros., 303 U. S. 177; Maurer v. Hamilton, 309 U. S. 598; Sproles v. Binford, 286 U. S. 374. The regulation of highways “is akin to quarantine [524] measures, game laws, and like local regulations of rivers, harbors, piers, and docks,' with respect to which the state has exceptional scope for the exercise of its regulatory power, and which, Congress not acting,- have been sustained even though they materially interfere with interstate commerce.” Southern Pacific Co. v. Arizona, 325 U. S. 761, 783.

These safety measures carry, a strong presumption of validity when challenged in court. If there are alternative ways of solving a problem, we do not sit to determine which of them is best suited to achieve a valid state objective. . Policy decisions are for the state legislature, absent federal entry into the field.5 Unless we can conclude on the' whole record.that “the total effect of the. law as a saféty measure in reducing accidents and casualties is so slight or problematical as not to outweigh the national interest in keeping interstate commerce free from interferences which seriously impede it” (Southern Pacific Co. v. Arizona, supra, pp. 775-776) we must uphold the statute.

The District-Court found that “since it is impossible for a carrier operating in interstate commerce to determine which of its equipment will be used in a particular area, or on a particular day, or days, carriers operating into or through Illinois . . . will be required to equip all their trailers in accordance with the requirements of the Illinois Splash Guard statute.” With two possible exceptions [525] the mudflaps required in those States which have mudguard regulations would not1 meet the standards required by the Illinois statute. The cost of installing the contour mudguards is $30 or more per vehicle. The District Court found that the initial cost of installing those mudguards on all the trucks owned by the.appelle.es ranged, from $4,500 to $45,840. There was also evidence in the record to indicate that the cost of maintenance and replacement of these guards is substantial.

Illinois introduced evidence seeking to establish that contour mudguards had a decided safety factor in that they prevented the throwing of debris into.the faces of-drivers of passing cars and into the windshields of a following vehicle. But the District. Court in its opinion stated that it was “conclusively shown that the contour mud flap possesses no advantages over the conventional or straight mud flap previously required in Illinois and presently required in most of the states” (159 F. Supp., at 388) and that “there is rather convincing. testimony that use of the contour flap creates hazards previously unknown to those using the highways.” Id., at 390. These hazards were found to be occasioned by the fact that this new type of mudguard tended to cause an accumulation of heat in the brake drum, thus decreasing the effectiveness of brakes, and by the fact that they were susceptible of being hit and bumped when the trucks were backed up and of falling off on the highway.

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Bibb v. Navajo Freight Lines, Inc., 359 U.S. 520, 79 S. Ct. 962, 3 L. Ed. 2d 1003, 1959 U.S. LEXIS 1777 (1959).

359 U.S. 520 (Bibb v. Navajo Freight Lines, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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