Lebamoff Enterprises, Inc. v. Huskey

Dist. Ct. did not err in rejecting plaintiffs’ challenge to Indiana statute that prevented retail liquor stores from shipping wine to their customers via motor carrier and instead required that said retailers make deliveries of wine themselves or by their employees who had personally verified age of Indiana residents purchasing said wine. While plaintiffs argued that Indiana statute was preempted by Federal Aviation Administration Authorization Act, which precludes states from enacting laws relating to route or service of motor carriers, Ct. found that Indiana statute possessed strong presumption of validity so as to defeat instant preemption claim where statute fell within core power given to states to regulate manner of liquor sales under 21st Amendment. Ct. similarly rejected plaintiffs’ claim that Indiana statute violated Commerce Clause because it constituted undue burden on interstate commerce.