Inc. Baldwin v. G. A. F. Seelig

Baldwin v. G. A. F. Seelig, Inc. reinforced federal control over interstate commerce, making it difficult for states to use alleged health concerns as a pretext for keeping out products from other states in order to protect their own industries.

G. A. F. Seelig, Inc. was a milk distributor that bought its milk from a creamery in Fair Haven, Vermont and sold it in its home state of New York. Every day, the company purchased some 200 cans of milk and 20 cans of cream, a "can" being equal to 40 gallons. Seelig sold 90 percent in the original cans to hotels, restaurants, and other large facilities. The remaining 10 percent was repackaged in individual bottles and sold directly to consumers.

Under the New York Milk Control Act, dealers such as G. A. F. Seelig had to pay producers (such as the creamery in Vermont) a certain price for milk. If they paid less, the state commissioner of farms and markets would refuse to license the sale of the milk in the state of New York. The price G. A. F. Seelig paid was below the minimum, and therefore the commissioner denied the company a license to sell its milk within the state. Seelig filed suit against the state, in the person of Baldwin and other officials, and the case went to the District Court of the United States for the Southern District of New York. The court issued a split decree: with regard to the milk sold in the "original packages" or cans, Seelig indeed had a right to resell it in New York. However, the court ruled for Baldwin and the state with regard to the repackaged, consumer-sized bottles.