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Here is an excerpt of the Legal Analysis for
FLORIDA LIME & AVOCADO GROWERS, INC. V. PAUL, DIRECTOR DEPARTMENT OF AGRICULTURE OF CALIFORNIA
373 U.S. 132 (1963)
LEGAL ANALYSIS: We bolded what was really important in the case. Any state legislation which frustrates the full effectiveness of federal law is rendered invalid by the Supremacy Clause. Focus on “whether the purposes of the two laws are parallel or divergent” tends to “obscure more than aid” in determining whether state law is pre-empted by federal law.
Here is a great summary of preemption doctrine taken from Dean’s Law Dictionary. There is more in the dictionary. You can see that this case is a poster child for conflict preemption.
Preemption doctrine (express or implied): Preemption may be either expressed or implied, and “is compelled whether Congress' command is explicitly stated in the statute's language or implicitly contained in its structure and purpose.” Jones v. Rath Packing Co., 430 U.S. 519, 525 (1977); Shaw v. Delta Air Lines, Inc., 463 U.S. 85, 95 (1983); Fidelity Fed. Sav. & Loan Assn. v. De la Cuesta, 458 U.S. 141, 152-153 (1982). Absent explicit pre-emptive language, courts have recognized at least two types of implied pre-emption: field pre-emption, where the scheme of federal regulation is “‘so pervasive as to make reasonable the inference that Congress left no room for the States to supplement it,’” id., at 153 (quoting Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 (1947)), and conflict pre-emption, where “compliance with both federal and state regulations is a physical impossibility,” Florida Lime & Avocado Growers, Inc. v. Paul, 373 U.S. 132, 142-143 (1963), or where state law “stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress,” Hines v. Davidowitz, 312 U.S. 52, 67 (1941); Felder v. Casey, 487 U.S. 131, 138 (1988); Perez v. Campbell, 402 U.S. 637, 649 (1971). A court's ultimate task in any pre-emption case is to determine whether state regulation is consistent with the structure and purpose of the statute as a whole. Looking to “the provisions of the whole law, and to its object and policy,” Pilot Life Ins. Co. v. Dedeaux, 481 U.S. 41, 51 (1987) (internal quotation marks and citations omitted). In determining whether state law “stands as an obstacle” to the full implementation of a federal law, Hines v. Davidowitz, 312 U.S., at 67, “it is not enough to say that the ultimate goal of both federal and state law” is the same, International Paper Co. v. Ouellette, 479 U.S. 481, 494 (1987). “A state law also is pre-empted if it interferes with the methods by which the federal statute was designed to reach th[at] goal.” Ibid.; see also Michigan Canners & Freezers Assn., Inc. v. Agricultural Marketing and Bargaining Bd., 467 U.S. 461, 477 (1984) (state statute establishing association to represent agricultural producers pre-empted even though it and the federal Agricultural Fair Practices Act “share the goal of augmenting the producer's bargaining power”); Wisconsin Dept. of Industry v. Gould Inc., 475 U.S. 282, 286-287 (1986) (state statute preventing three-time violators of the National Labor Relations Act from doing business with the State is pre-empted even though state law was designed to reinforce requirements of federal Act).
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