The State of New Jersey was concerned about its overburdened landfills and the hazards they posed to the state’s environment. To address the issue, the state passed a law that barred other states from shipping garbage into the state for deposit in New Jersey landfills.
In response, private landfill owners and the City of Philadelphia brought suit against the state, arguing that the law violated the Dormant Commerce Clause. The Dormant Commerce Clause bars states from doing anything that improperly burdens or discriminates against interstate commerce.
The United States Supreme Court took up the case in City of Philadelphia v. New Jersey, 437 U.S. 617 (1978), to decide whether a state could prohibit the deposit of out-of-state waste in landfills within its borders without running afoul of the Dormant Commerce Clause.
Ultimately, a majority of the Court struck down the New Jersey statute, concluding that the state had unconstitutionally discriminated against articles of commerce based on their out-of-state origin. This was a landmark case for the Court’s holding that a state could not pass even health-and-safety regulations designed to protect its own citizens that unduly burden or discriminate against interstate commerce.
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