Monroe-Livingston Sanitary Landfill, Inc., Appellant v. Town of Caledonia, Respondent

Summary

The New York Court of Appeals affirmed the Appellate Division, holding that the Town of Caledonia's sanitary landfill ordinance is not preempted by the Environmental Conservation Law and does not violate the interstate commerce clause. The majority reasoned that the statute expressly permits local regulation consistent with minimum state requirements and that the ordinance has no practical effect on interstate commerce because the plaintiff does not handle out‑of‑state refuse. Justice Fuchsberg dissented, arguing that the ordinance conflicts with the commerce clause and should be struck down.