Allenberg Cotton Co. v. Pittman

In Allenberg Cotton Co. v. Pittman (1974) 419 U.S. 20, a Tennessee merchant purchased cotton from a Mississippi farmer through the efforts of a Mississippi broker and temporarily stored the cotton in a Mississippi warehouse before distributing the cotton nationally. A Mississippi court dismissed the merchant's suit for breach of contract on the ground that the merchant had not complied with the state's qualification statute. After an extended discussion of the complexities of the cotton market the Supreme Court described dismissal of the suit as "a species of control over an intricate interstate marketing mechanism" ( id. at p. 29) and held it to be repugnant to the commerce clause. ( Id. at p. 34.) The court viewed itself as reaffirming the rule that one who merely traffics in goods of a peculiarly interstate nature, e.g., wheat, livestock, and milk ( id. at pp. 29-31), without establishing local contacts in an individual state ( id. at p. 33), cannot be regulated by the latter.