Florida Lime & Avocado Growers v. Paul
Citation
373 U.S. 132 (1963)
Facts
California’s agricultural code prohibited the sale of avocados that did not meet a certain oil content standard for maturity, while a federal marketing order used a different maturity standard based on other criteria. Florida avocado growers argued the California standard was preempted by the federal order.
Issue
Whether California’s avocado maturity standard is preempted by a conflicting federal marketing order establishing a different maturity standard.
Holding
The Court upheld California’s law, finding that simultaneous compliance with both standards was possible and that the California law did not stand as an obstacle to federal objectives.
Rule
Conflict preemption requires either impossibility of simultaneous compliance or that the state law stands as an obstacle to accomplishing federal objectives; a mere difference in standards does not establish preemption.