Флорида авокадо өндірушілерінің ісі және Калифорния штатының стандарттары

Florida Lime & Avocado Growers, Inc. v. Paul, 373 U. S. 132 (1963), was a 1963 decision of the United States Supreme Court in which the Court declined to invalidate a California law that imposed minimum fat content standards on avocados sold in the state, including those imported from other states. The law prohibited the sale of avocados that did not contain at least 8% oil by weight. Florida, a major avocado producer, employed, for wholesale marketing purposes, a federal standard unrelated to oil content. Most Florida avocados that were marketable at home failed to meet the California standard, because they were a different variety from those sold in California, with a lower fat content. Accordingly, Florida avocado growers brought this suit, arguing (unsuccessfully) that the California law (1) was preempted by federal law, (2) violated equal protection, and (3) unduly burdened and interfered with their right to engage in interstate commerce. The case is widely used in law school casebooks on constitutional law and federal jurisdiction as illustrative of preemption issues.

There are three principal races or groups of avocado: Mexican, Guatemalan and West Indian, named for the areas where they were originally cultivated. Mexican avocados have foliage with an anise scent and small fruits about the size of a plum, with black or purple smooth skin. Guatemalan avocados have larger, blackish green, rough skinned fruits. The West Indian avocado has the largest fruits, up to 2 lbs (1 kg), with smooth light green skin. Mexican avocados have the highest oil content; West Indian the lowest. The important cultivars now in commercial production are mostly hybrids between these three original races. In 1925, California enacted a law requiring that "all avocados, at the time of picking, and at all times thereafter, shall contain not less than 8 percent of oil, by weight of the avocado excluding the skin and seed." In 1925, practically all the avocados in the United States came from California. The purpose of this legislation was to prevent the marketing of immature avocados, which never ripen properly, but decay or shrivel up and become rubbery and unpalatable. The effect of marketing immature avocados is to antagonize consumers; this increases future sales resistance against buying avocados. In 1925, most of the avocados grown in California were, as they are at the present time, from trees derived from Mexican varieties (e. g. Haas avocados). Such avocados contain at least 8% oil when mature. The Florida avocado growers, however, mostly cultivate West Indian, Guatemalan, and hybrid varieties, which may reach maturity and be acceptable and reach their prime for marketing prior to reaching an 8% oil content, or they may never reach that level of oil content. All members of the Court agreed that there is no health issue; the question is "a purely economic one." The Florida avocado growers objected to the California law because it severely restricts the access of Florida growers to the California market. While California's avocado maturity standard is provided by statute, Florida's is set by a marketing order under the Agricultural Adjustment Act (AAA), a New Deal measure creating a regime of self government for farmers, designed to "promote orderly competition among the South Florida growers" of avocados. The marketing orders for avocados are drafted by the South Florida Avocado Administrative Committee, which consists entirely of representatives of the growers concerned. The Secretary of Agriculture invariably adopts the committee's recommendations for avocado maturity dates, sizes, and weights.

Justice William J. Brennan delivered the 5 4 opinion of the Court, joined by Chief Justice Earl Warren, and Justices John Marshall Harlan II, Potter Stewart, and Arthur J. Goldberg.

The Court affirmed the district court's conclusion that the state standard does not work an irrational discrimination as between persons or groups of persons." While "it may well be" that arguably superior tests of maturity could be devised than the 8% oil test, this possibility does not make the state's choice "either arbitrary or devoid of rational relationship to a legitimate regulatory interest." That is not a question for the courts to decide, and "it is sufficient that, on this record, we should conclude, as we do, that oil content appears to be an acceptable criterion of avocado maturity."

California cross appealed on the ground that the district court should have dismissed the action for want of equity, rather than for lack of merit. The contention is that there was no justiciable controversy and an insufficient showing of injury (there must be an irreparable injury) to the Florida growers to invoke the district court's equity jurisdiction. The Court rejected both arguments. First, in the earlier appeal, Florida Lime & Avocado Growers, Inc. v. Jacobsen,

A June 2016 article in the Wall Street Journal describes the current state of the Avocado War between Florida and California. J. R. Brooks (now Brooks Tropicals LLC), the successful plaintiff in the remand after the Supreme Court opinion, established the trademark "SlimCados" to designate several different Florida avocado varieties that it markets. Brooks promotes the lower fat content of Florida avocados as a desirable diet feature in "trying to compete with California's Hass variety, which accounts for 95% of the American avocado market and 80% of global demand." However, according to the Journal, "the oversize SlimCados look like a guacamole lover's dream," because their weight is up to six times that of a Hass, but "their different taste has left many disappointed, making them the avocado some foodies love to hate." The Journal quotes one detractor of Florida avocados as complaining, "I've never felt so betrayed by a piece of food in my life," because the Florida "avocado's innards were watery, producing a soupy guacamole that lacked the rich, creamy flavor she craved."