Legato Vapors, LLC v. Cook

Indiana statute, which regulated design and operation of out-of-state production facilities of manufacturers of “e-cigarettes” that included requirements for sinks, cleaning products and details of contracts with outside security firms, violated dormant Commerce Clause of U.S. Constitution, since it improperly regulated commercial activity outside of Indiana. Moreover, while Indiana could impose reasonable requirements on vaping products sold in Indiana, it could not attempt to achieve such goal by direct extraterritorial regulation of manufacturing processes and facilities of out-of-state manufacturers. As such, Dist. Ct. erred in granting defendants’ motion for summary judgment in action challenging said statute.