1959 United States Supreme Court case
Bibb v. Navajo Freight Lines, Inc. Argued March 30–31, 1959 Full case name Bibb, Director, Department of Public Safety of Illinois v. Navajo Freight Lines, Inc., et al. Citations 359U.S. 520 (more Case history Prior Appeal from theUnited States District Court for the Southern District of Illinois Holding TheIllinois law requiring trucks to have mudguards was unconstitutional under theCommerce clause . Court membership Chief Justice Earl Warren Associate Justices Hugo Black · Felix Frankfurter William O. Douglas · Tom C. Clark John M. Harlan II · William J. Brennan Jr. Charles E. Whittaker · Potter Stewart Case opinions Majority Douglas, joined by Warren, Black, Frankfurter, Clark, Brennan, Whittaker Concurrence Harlan, joined by Stewart Laws applied Commerce clause Article 1, Section 8, Paragraph 3: Interstate Commerce Clause
Bibb v. Navajo Freight Lines, Inc. United States Supreme Court case in which the Court held that theIllinois law requiring trucks to have unique mudguards was unconstitutional under theCommerce clause .
The state ofIllinois enacted astatute requiring curvedmud guards , instead of straightmudflaps on trucks driven in Illinois. Although there was no federal regulation requiring mudflaps or mudguards,Arkansas required straight mudflaps, which were legal in at least 45 states.[ 1] New Mexico .
The only issue was whether in the absence of federal regulation, in this context did theCommerce Clause 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 [ edit ] The Supreme Court held that the Illinois law was unconstitutional under theCommerce clause , technically theDormant Commerce Clause .
InBibb v. Navajo Freight Lines , 359 U.S. 520, 524 (1959), the Supreme Court stated:
These safety measures carry a strong presumption of validity when challenged in court. If there are alternative ways of solving a problem, we do not sit to determine which of them is best suited to achieve a valid state objective. Policy decisions are for the state legislature, absent federal entry into the field. Unless we can conclude on the whole record that "the total effect of the law as a safety measure in reducing accidents and casualties is so slight or problematical as not to outweigh the national interest in keeping interstate commerce free from interferences which seriously impede it we must uphold the statute."
— Bibb v. Navajo Freight Lines, Inc.
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
This is one of those cases—few in number—where local safety measures that are nondiscriminatory place an unconstitutional burden on interstate commerce.
— Bibb v. Navajo Freight Lines, Inc.
Subsequent developments [ edit ] It is considered one of the leadingprecedents on the law ofInterstate commerce .[citation needed
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