''Bibb v. Navajo Freight Lines, Inc.'', 359 U.S. 520 (1959), is a

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

case in which the Court held that the

Illinois Illinois ( ) is a U.S. state, state in the Midwestern United States, Midwestern United States. Its largest metropolitan areas include the Chicago metropolitan area, and the Metro East section, of Greater St. Louis. Other smaller metropolita ...

law requiring trucks to have unique mudguards was unconstitutional under the

Commerce clause The Commerce Clause describes an enumerated power listed in the United States Constitution ( Article I, Section 8, Clause 3). The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and amon ...

Background

The state of

enacted a

statute A statute is a formal written enactment of a legislative authority that governs the legal entities of a city, state, or country by way of consent. Typically, statutes command or prohibit something, or declare policy. Statutes are rules made by le ...

requiring curved

mud guard A mudflap or mud guard is used in combination with the vehicle fender to protect the vehicle, passengers, other vehicles, and pedestrians from mud and other flying debris thrown into the air by the rotating tire. A mudflap is typically made fro ...

s, instead of straight

mudflap A mudflap or mud guard is used in combination with the vehicle fender to protect the vehicle, passengers, other vehicles, and pedestrians from mud and other flying debris thrown into the air by the rotating tire. A mudflap is typically made from ...

s on trucks driven in Illinois. Although there was no federal regulation requiring mudflaps or mudguards,

Arkansas Arkansas ( ) is a landlocked state in the South Central United States. It is bordered by Missouri to the north, Tennessee and Mississippi to the east, Louisiana to the south, and Texas and Oklahoma to the west. Its name is from the Osage ...

required straight mudflaps, which were legal in at least 45 states. The Illinois legislature asserted that the unique curved mudguards would be more useful in preventing stones and other debris to be kicked up from the back of trucks, thus preventing more accidents than other types of mudflaps. The plaintiffs were trucking companies who drove through Illinois and would have to use one form of mudflap equipment while in Illinois, but other mudflap equipment while in other states. The named plaintiff was Navajo Freight Lines, Inc., of

New Mexico ) , population_demonym = New Mexican ( es, Neomexicano, Neomejicano, Nuevo Mexicano) , seat = Santa Fe , LargestCity = Albuquerque , LargestMetro = Tiguex , OfficialLang = None , Languages = English, Spanish ( New Mexican), Navajo, Ker ...

. The only issue was whether in the absence of federal regulation, in this context did the

Commerce Clause The Commerce Clause describes an enumerated power listed in the United States Constitution ( Article I, Section 8, Clause 3). The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and amon ...

allow one State to prescribe standards that would affect interstate carriers in a way that would conflict with the standards of another State.

Opinion of the Court

The Supreme Court held that the Illinois law was unconstitutional under the

, technically the

Dormant Commerce Clause The Dormant Commerce Clause, or Negative Commerce Clause, in American constitutional law, is a legal doctrine that courts in the United States have inferred from the Commerce Clause in Article I of the United States Constitution, Article I of the U ...

. In ''Bibb v. Navajo Freight Lines'', 359 U.S. 520, 524 (1959), the Supreme Court stated: The court was unanimous, but Justice Harlan filed a concurrence, which was joined by Justice Stewart. To find the statute unconstitutional, the Court balanced the benefit of the regulation to the state (in the form of increased safety) against the burden on interstate commerce arising from out of state truck drivers having to stop at the Illinois border and change mudguards. Because the benefit to Illinois was small and the burden on interstate commerce large, the Court held that

Subsequent developments

It is considered one of the leading

precedent A precedent is a principle or rule established in a previous legal case that is either binding on or persuasive for a court or other tribunal when deciding subsequent cases with similar issues or facts. Common-law legal systems place great valu ...

s on the law of

Interstate commerce The Commerce Clause describes an enumerated power listed in the United States Constitution ( Article I, Section 8, Clause 3). The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and among ...

References

External links

* {{Trucking industry in the United States, state=collapsed United States Constitution Article One case law United States Supreme Court cases United States Dormant Commerce Clause case law 1959 in United States case law Legal history of Illinois Vehicle law Transport case law Trucking industry in the United States United States Supreme Court cases of the Warren Court Automotive accessories

Background

Opinion of the Court

Subsequent developments

See also

References

External links