Rowe v. New Hampshire Motor Transp. Assn., 552 U.S. 364 (2008)
Primary Holding
The federal law pre-empts state laws that regulate the delivery of tobacco products when those regulations are related to the price, route, or service of motor carriers, as established by the Federal Aviation Administration Authorization Act of 1994.
In the case of Rowe v. New Hampshire Motor Transport Association, the Supreme Court decided that federal law overrides state laws that try to control how tobacco products are delivered, especially when it involves pricing and transportation. This matters because it means that states can't impose their own rules that might interfere with how trucking companies operate when delivering tobacco, which can affect the availability and pricing of these products. For consumers, this ruling is relevant if you find that state laws are limited in regulating the delivery of tobacco products, as it ensures a more uniform approach across states, but may also limit local efforts to control tobacco sales.
AI-generated plain-language summary to help you understand this case
In Rowe v. New Hampshire Motor Transport Association, the underlying dispute arose from the State of Maine's enactment of a tobacco regulation law in 2003, which included two specific provisions affecting the delivery of tobacco products. The first provision mandated that only Maine-licensed tobacco retailers could accept orders for tobacco delivery, and it required that these retailers use a delivery service that verifies the recipient's identity and age. The second provision prohibited the transportation of tobacco products to individuals in Maine unless the sender or receiver held a Maine license. Violations of these provisions could result in significant civil penalties. The case reached the Supreme Court after the New Hampshire Motor Transport Association challenged the Maine law, arguing that it was pre-empted by federal law. Specifically, they contended that the Federal Aviation Administration Authorization Act of 1994, which prohibits states from enacting laws related to the price, route, or service of motor carriers, invalidated the Maine regulations. The case was initially heard in lower courts, where the federal pre-emption argument was raised, leading to an appeal that culminated in the Supreme Court's review. The relevant background context includes the broader legislative framework established by Congress to deregulate the transportation industry, which began with the Airline Deregulation Act of 1978 and continued with the Motor Carrier Act of 1980 and subsequent laws. These federal statutes were designed to prevent states from imposing regulations that could interfere with the competitive market dynamics of the transportation sector. The Maine tobacco law was seen as a potential infringement on this federal pre-emption, prompting the legal challenge that led to the Supreme Court's decision.
Whether a federal statute that prohibits States from enacting any law “related to” a motor carrier “price, route, or service” pre-empts provisions of a Maine tobacco law regulating the delivery of tobacco to customers within the State.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 28, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Breyer
- Damages Awarded
- N/A
- Data Quality
- high
Altria Group, Inc. v. Good, 555 U.S. 70 (2008)
Consumer WonThe Federal Cigarette Labeling and Advertising Act does not expressly or impliedly pre-empt state-law claims regarding fraudulent advertising practices, allowing consumers to pursue claims under state unfair trade practices laws.
Mid-Con Freight Systems, Inc. v. Michigan Pub. Serv. Comm'n, 545 U.S. 440 (2005)
Consumer LostThe federal statute regarding interstate commerce pre-empts state registration requirements only if they impose an unreasonable burden, and the Michigan law imposing a $100 annual fee on trucks operating entirely in interstate commerce does not constitute such a burden, thus it is not pre-empted by federal law.
Watson v. Philip Morris Cos., 551 U.S. 142 (2007)
Consumer WonThe federal officer removal statute does not permit a defendant to remove a state-court action to federal court simply because a federal regulatory agency directs, supervises, and monitors the company’s activities in detail; the company must be acting under the direct authority of a federal officer in relation to the specific conduct being challenged.
American Trucking Assns., Inc. v. Michigan Pub. Serv. Comm'n, 545 U.S. 429 (2005)
Consumer LostThe flat $100 fee imposed by Michigan on trucks engaged in intrastate commercial hauling does not violate the dormant Commerce Clause, as it is regulatory in nature, applies evenhandedly, and does not impose an unconstitutional burden on interstate trade.