California Retail Liquor Dealers Association v. Midcal Aluminum Inc. (1980)

This case regarded commerce. The commerce clause granted congress the power to regulate trade among states. Under section two of the twenty-first Amendment, the commerce clause gives states the power to control “the transportation or implementation of alcoholic beverages.”(Scholarly Commons) The controversy lay in the amount of power the states had to regulate the importation and sale of liquor.

In California Retail Liquor Dealers Ass’n v. Midcal Aluminum Inc. however, the Supreme Court attempted to “define the relationship between states power under the twenty-first Amendment and federal power under the commerce clause.” In this case, the state of California (California Department of Alcoholic Beverage Control) charged Midcal Aluminum Inc. for selling twenty seven cases of wine below set price under the state’s wholesale wine pricing laws.

Midcal was a wholesale distributor of wine. Under the California statute, Midcal faced fines or license suspension or revocation. However, Midcal responded to this charge by filing a suit in the California Court of Appeals requesting an injunction. The California Court of Appeals ruled in favor of Midcal, stating that the California statute was a violation of the Sherman Act as it restricted trade and was a liability under the “state action” doctrine and thus granted Midcal an injunctive relief.

The Court declared that the statute violated the Sherman act and refused to grant antitrust immunity. Other than Justice Brennan who took no part in the consideration and decision of the case, the court decision was unanimously in favor of the respondents Midcal Aluminum and the opinion was read by Justice Powell.


“California Retail Liquor Dealers Assn. v. Midcal Aluminum, Inc.” Oyez. Chicago-Kent College of Law at Illinois Tech, n.d. Dec 6, 2015.

“Midcal Aluminum, Inc. V. California Retail Liquor Dealers Association: Federal Power under the Twenty-First Amendment.” Washington and Lee Law Review, n.d. Web. 12 Dec. 2015.

“SOUTH DAKOTA v. DOLE, 483 U.S. 203 (1987).” SOUTH DAKOTA v. DOLE, 483 U.S. 203 (1987). N.p., n.d. Web. 06 Dec. 2015.

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