Module 2 - IRAC Analysis

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Module 2 - IRAC Analysis by Mind Map: Module 2 - IRAC Analysis

1. Family Winemakers of California v. Jenkins (United States Court of Appeals, First Circuit, 592 F.3d 1 (2010)

1.1. Facts

1.1.1. Parties Family Winemakers of California Eddie J. Jenkins Chair of the Massachusetts Alcoholic Beverages Control Commission

1.1.2. What happened History 21st Amendment ended prohibition and states took control of regulations Typical regulation is three-tier system Some allowance of direct shipping from producers to consumers Massachusetts wineries are small in production and typically have a more difficult time getting wholesaler distribution Massachusetts action 2005 - Law to only allow in-state wineries to obtain licenses for direct shipment and normal distribution 2006 - Law to only allow producers of less than 30,000 gallons to obtain licenses for direct shipment and normal distribution Impact Small wineries had a competitive advantage in direct distribution "large wineries" category only impacted outside of Massachusetts

1.1.3. Procedural History Commerce Clause made 2005 legislative action illegal due to discriminator nature Family Winemakers of California brought suit against Eddie J. Jenkins as representative of the Massachusetts Alcoholic Beverages Control Commission

1.2. Issue before the Court

1.2.1. Whether the legislative action to limit direct to consumer distribution of wine violated the Commerce Clause by 1) Differentiating in-state and out-of-state interests 2) That benefit the in-state parties beyond incidental impact

1.3. Rule of Law

1.3.1. Necessary elements of a Commerce Clause claim Plaintiff must show that the in-state parties benefited from the legislative action beyond incidental impact Defendants must prove that if discrimination occurred, there is a legitimate reason that could not be achieved in a non-discriminatory way

1.4. Application

1.4.1. Family Winemakers of California argue that the law gives a competitive advantage to in-state wine makers The court agreed that the law gave a competitive advantage to Massachusetts wine producers Since the court agreed that law was discriminatory, then the state had to prove constitutionality due to a legitimate purpose that can't be achieve without discrimination The state failed to prove this Furthermore a non discriminatory proposal existed by the governor to allow all winemakers, regardless of size, to use the direct distribution method


1.5. Conclusion

1.5.1. The court found for the plaintiff that the 2006 legislation was discriminatory to out-of-state winemakers and violated the Commerce Claus

1.5.2. Impact Solidified strike down of similar laws in Michigan and New York as well as various legislation in the other states

1.5.3. Why we care This case highlights the limits a state legislature can  push to promote in-state business It also challenges the 21st amendment rights of state to regulate alcohol This is notable to a business professional lobbying for legislative preference over out-of-state competitors

1.5.4. Practices influenced by case State legislatures are no longer able to give competitive advantage to in-state producers State legislatures influence was curtailed

2. Todd LeClair