United States v. Robert J. Taylor

752 F.2d 757
CourtCourt of Appeals for the First Circuit
DecidedApril 10, 1985
Docket84-1699
StatusPublished
Cited by8 cases

This text of 752 F.2d 757 (United States v. Robert J. Taylor) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Robert J. Taylor, 752 F.2d 757 (1st Cir. 1985).

Opinion

*759 MALETZ, Senior Judge.

A Maine statute provides: “A person is guilty of importing live bait if he imports into this state any live fish, including smelts, which are commonly used for bait fishing in inland waters.” Me.Rev.Stat. Ann. tit. 12, § 7613 (1981). The question presented is whether this statute violates the Commerce Clause, art. I, § 8, cl. 3, of the United States Constitution. We hold that it does and accordingly reverse the district court’s denial of defendant’s motion to dismiss his indictment under that statute.

I. Background

Defendant was charged in a two-count indictment under the Lacey Act Amendments of 1981, 16 U.S.C. §§ 3372 and 3373 (1982), which proscribe the importation in interstate commerce of any fish or wildlife taken, possessed, transported, or sold in violation of state law. Id. § 3372(a)(2)(A). 1 The indictment, which included a conspiracy count ^.nd a substantive count, alleged that defendant imported into the State of Maine live golden shiners 2 in violation of the blanket prohibition of Me.Rev.Stat.Ann. tit. 12, § 7613. Defendant moved to dismiss the indictment on the ground that the statute violated the Commerce Clause. The district court accepted the magistrate’s recommended decision and denied the motion. It concluded that, while the statute discriminated against interstate commerce, it served a legitimate local purpose and that less discriminatory alternatives were not available. 585 F.Supp. 393 (D.Me. 1984). Defendant then entered a conditional plea of guilty and reserved his appellate rights. Fed.R.Crim.P. 11(a)(2). 3 This appeal followed.

II. Contentions of the Parties

The government and intervenor State of Maine concede that section 7613 discriminates facially against interstate commerce. They contend that the statute nevertheless should survive Commerce Clause scrutiny because of (1) Maine’s vital interest in excluding fish parasites and exotic species and (2) the unavailability of alternative means that could promote this environmental purpose. The government argues that, in any event, whatever the legitimacy of section 7613 under the Commerce Clause, it is validated by “congressional consent.” 4

The government lists three parasites that might appear in imported bait fish and threaten Maine’s indigenous wild fish population: (1) Capillaria catastomi, (2) Pleistophera ovariae, and (3) Bothriocephalus opsalichthydis (Asian tapeworm). It also contends that exotic fish species, which mingle with live bait fish, could enter Maine’s waters and damage the native fish population as competitors or predators. According to the government, scientists have not agreed upon sampling and certification procedures that would assure disease-free warm water bait fish. Since golden shiners are extremely small fish, 5 inspection of each fish is concededly impossible.

For his part, defendant introduced evidence that the parasites and exotic species are not a serious threat and that Maine permits importation of other fish that pose analogous problems. 6 In addition, defend *760 ant argues that less burdensome regulatory alternatives are available to Maine and that section 7613 is no more than economic protectionism in the guise of environmentalism. 7 In support of the latter contention, defendant points to a statement submitted by the Maine Department of Inland Fisheries and Wildlife to the Legislature at a time that repeal of the ban on importation of bait fish was being considered. 8 In part, the statement reads:

[W]e can’t help asking why we should spend our money in Arkansas when it is far better spent .at home? It is very clear that much more can be done here in Maine to provide our sportsmen with safe, home-grown bait. There is also the possibility that such an industry could develop a lucrative export market in neighboring states.

III. The Commerce Clause

The Commerce Clause provides that “Congress shall have Power ... To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes.” The Clause exerts an impact beyond its literal language:

Although the Commerce Clause is by its text an affirmative grant of power to Congress to regulate interstate and foreign commerce, the Clause has long been recognized as a self-executing limitation on the power of the States to enact such laws imposing substantial burdens on such commerce. [Citations omitted.] It is equally clear that Congress “may redefine the distribution of power over interstate commerce” by “permit[ting] the states to regulate the commerce in a manner which would otherwise not be permissible.”

South-Central Timber Dev., Inc. v. Wunnicke, — U.S. —, —, 104 S.Ct. 2237, 2240, 81 L.Ed.2d 71 (1984) (quoting Southern Pacific Co. v. Arizona ex rel. Sullivan, 325 U.S. 761, 769, 65 S.Ct. 1515, 1520, 89 L.Ed. 1915 (1945)). In its role as an implied limitation on state power, the Clause is referred to, interchangeably, as the negative Commerce Clause 9 or the dormant Commerce Clause. 10

The Supreme Court has formulated a three-part test for evaluation of state statutes under this Clause:

[W]e must inquire (1) whether the challenged statute regulates evenhandedly with only “incidental” effects on interstate commerce, or discriminates against interstate commerce either on its face or in practical effect; (2) whether the statute serves a legitimate local purpose; and, if so, (3) whether alternative means could promote this local purpose as well without discriminating against interstate commerce.

Hughes v. Oklahoma, 441 U.S. 322, 336, 99 S.Ct. 1727, 1736, 60 L.Ed.2d 250 (1979) (invalidating statute that placed no limit on number of minnows that could be taken by licensed minnow dealers but fos?bade any person from leaving the state with more than three dozen minnows). See Pike v. Bruce Church, Inc., 397 U.S. 137, 142, 90 S.Ct.

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Bluebook (online)
752 F.2d 757, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-robert-j-taylor-ca1-1985.