Florida Lime & Avocado Growers, Inc. v. Paul Case Brief

Facts of the Case

“California’s Agricultural Code prohibits the transportation or sale in the state of avocados which contain “less than 8% of oil, by weight standards, weight excluding the skin and seed.” On the other hand, Federal marketing orders approved by the Secretary of Agriculture gage the maturity of avocados grown in Florida by standards, which attribute no significance to the oil content. This means that CA markets FL avocados which satisfy Federal law, but not California law. Plaintiffs challenged the law under the Constitution’s Supremacy and Commerce clauses.”


Did the trial court commit a plain error when it failed to consider evidence of Eddings’ unhappy childhood and emotional disturbance in its consideration of mitigating and aggravating circumstances?


“Preemption does not arise if there is no direct conflict between federal and state laws, meaning that it is possible to comply with both of them simultaneously, and if the state law does not frustrate the purpose of the federal law.In an opinion authored by Justice William Brennan, the Court held that federal law will preempt a state law if it is physically impossible to comply with both laws. In this situation, it would be possible to comply with both laws, since the Florida growers could have met the California standard if they had allowed their avocados more time to grow. This means that there was no inherent conflict between the two laws.Justices White, Black, Douglas, and Clark dissented on the ground that the California statute was invalid under the Supremacy Clause of the Federal Constitution.”

Case Information

Citation: 373 US 132 (1963)
Argued: Jan 8, 1963
Decided: May 13, 1963
Case Brief: 1963