Rocky Mountain Farmers Union v. Goldstene, 730 F.3d 1070 (9th Cir. 2013)
Rocky Mountain Farmers Union v. Goldstene addresses the tension between state-level environmental regulatory efforts and the federal interest in preserving an open national market.
Does the California Low Carbon Fuel Standard unconstitutionally discriminate against interstate commerce or regulate extraterritorially in violation of the Commerce Clause?
Under the Commerce Clause, state laws that regulate commerce must not discriminate against or unduly burden interstate commerce and must not control commerce occurring wholly outside of the state.
The Ninth Circuit held that California's LCFS does not facially discriminate against out-of-state commerce. The court found that the LCFS primarily addresses local environmental concerns without being merely a means to give economic advantages to in-state producers.
Rocky Mountain Farmers Union v. Goldstene matters greatly in our emerging understanding of how states can regulate for environmental goals without infringing upon constitutional commerce mandates. This case clarifies the scope of state power under the Commerce Clause. Law students can learn how courts evaluate the legitimacy of state regulations that have national impact, and the decision serves as a precedent for assessing similar regulations by other states regarding their extraterritorial effects.