Alexis Bailly Vineyard, Inc. v. Harrington, No. 18-1846 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit reversed the district court's order granting summary judgment to the Commissioner, in an action brought by Farm Wineries seeking a declaration that the Minnesota Farm Wineries Act's in-state requirements violates the dormant Commerce Clause. The court held that the Farm Wineries had Article III standing, because they established an injury in fact by alleging that they were presently injured by the Act because they cannot plan for and expand their businesses. Furthermore, the Farm Wineries' injuries were fairly traceable to the in-state requirement, because the Commissioner has the authority to enforce the Act against the Farm Wineries. Finally, Farm Wineries' injuries can be redressed by a declaratory judgment. Accordingly, the court remanded for further proceedings.
Court Description: Kobes, Author, with Shepherd and Erickson, Circuit Judges] Civil case - Minnesota Farm Wineries Act. The district court erred in determining plaintiffs, Minnesota wineries, did not have standing to bring a pre-enforcement challenge to the Minnesota Farm Wineries Act - Minn. Stat. Sections 340A.201, 304A.401, requiring them to manufacture their wine with a majority of the ingredients grown or produced in Minnesota; the plaintiffs are the object of the Act and subject to future enforcement actions brought by the Commissioner of the Minnesota Department of Public Safety and thus have standing to challenge the Act's constitutionality; plaintiffs have injuries traceable to the in-state requirement and their injury can be redressed by a declaratory judgment.
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