WK 3.1
31/7/00
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Airlines of NSW (No 2) states that Cth can regulate intrastate aviation (the physical aspects of it) when necessary to make interstate & foreign effective.
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“necessity to make effective” (Dixon J in Burgess) is link betw’n intrastate & interstate & is indicative of implied incidental pwr.
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so allowed to regulate not because fell within core pwr (because not interstate or foreign) but because of physical aspects (dangers of multiple control said to be incidental).
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What about if economic necessity to regulate intrastate so as to make effective regulation of interstate? This was not argued in the true sense in Airlines of NSW (No 2). Reg 200B held invalid.
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“necessity to make effective” does not extend beyond physical aspects – Kitto J (pp 180-1) distinguishes betw’n eco (consequential matters) & safety (preservation of actual conduct).
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Why diff betw’n eco & physical factors (in particular safety)? Try to preserve a field of intrastate trade for the States (isn’t this ‘reserved state pwrs’ thinking – see Barwick CJ quoting Dixon J in Wragg).
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Western Australian Airlines Case (Ansett) Ctd
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necessity does not mean absolute necessity – diff’nt judges adopt diff’nt views [eg: Mason J is more liberal & sees necessity as meaning not strict necessity but “what is appropriate”].
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journey was from Perth to Darwin via Port Hedland [there is no constitutional prob with going Syd-Goulb-Can but there is one with Syd-Goulb-Melb (unless if just refuelling in Goulb latter is seen as interstate)].
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always a journey to territory.
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Stephen J: without stop over in PH, TAA was not interested in P-D [stop over was economically necessary (for TAA’s purpose)].
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Barwick CJ & Gibbs J: economic health of airline was not a relevant factor under either pwr [s 122, s 51(i)] and therefore prov was wholly invalid; TAA could not authorise stop over. [they still mention ‘reserved state pwrs’]
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Stephen J: s 51(i) is constrained by fact that intrastate commerce must be kept separate but not constrained by s 122 [‘reserved state pwr’ reasoning (?) – when you define Cth’s pwr by saying what is left to the State, this is ‘reserved state pwr’ thinking].
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Mason J: read down s 19(2), & therefore valid to territories & rest take out; no rigid reasoning to separate/distinguish eco & non-eco factors (p 190 para 1).
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Murphy J: to suggest American commerce clause is narrower than Aust is wrong; discusses s 51(i) & accuses maj of ‘reserved state pwrs’ thinking.
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Stephen J: can take eco factors into consideration but if you are merely using eco nexus in order for Cth to regulate intrastate commerce, this is wrong [ie, to use eco factors when considering intrastate commerce under s 51(i) is incorrect]; you can use eco factors when considering interstate (& things ancillary or subsequent to interstate commerce like production which is neither intrastate nor interstate) & in relation to s 122.
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See Mason J’s article (p 190) in which he states that improvements in transportation & communication have led to a merging of economies. Integration of Aust market has meant that interstate & foreign commerce has gotten larger.
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See Zines (p 191) who sets out 4 views regarding eco & commercial factors [view (d) that they always provide a sufficient basis is the modern view held by Mason & McHugh JJ]. However, with the rather conservative approach of HCA today, it would be difficult see how many of the justices would depart from precedence (in particular Dixon J).
Notes (p 189):
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4 justices considered s 51(i) when no interstate commerce was involved & s 19B could be read down to apply only to intrastate flights in the course of territorial commerce because it was argued & therefore felt obliged to answer to it (strictly unnecessary – Mason J).
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Outcome on s 51(i) would not have differed if s 19B(2) had spoken of economic necessity rather than “the efficient, competitive & profitable conduct” of TAA’s business because as Mason states (p 189) effectively the form of the leg’n is what amounts to necessity.
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Yes, Murphy J is right in accusing others of using “reserved state pwrs” thinking (although Barwick CJ would disagree).
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s 122 says that Cth can make laws for gov’nt of the Territory and can therefore be concerned with financial integrity of Territory (in 1976, it was before self-gov’nt, & Cth was gov’nt & TAA belonged to gov’nt). AS Murphy J states, this was for gov’nt air transport. So if Ansett were priv airline, diff’nt story.
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Today, diff’nt because Qantas is privatised & NT has self-gov’nt (s 122)
Today, as opposed to 5 yrs ago, HCA is more conservative & in relation to decision under s 51(i), it would be same.
US approach
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Absolutely no distinction betw’n physical & economic factors drawn in this area of trade & commerce.
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Congress can regulate intrastate commerce where it is economically necessary to do so (“substantially affects interstate or foreign commerce”).
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US commerce clause has been interpreted more broadly than s 51(i), enabling the reg’n of intrastate activities which have an eco impact on interstate or overseas trade.
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2 reasons why HCA has not adopted US approach:
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too loose & anything can be seen as having a substantial affect on interstate commerce.
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we have many more commercial pwrs than US:
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pwr over trading corporations [s 51(xx)]
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pwr over telecommunications [s 51(v)]
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arbitration over industrial disputes [s 51(xxxv)]
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banking [s 51(xiii)]
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insurance [s 51(xiv)]
& because US does not have these, everything goes under the commerce pwr in the US [see Mason’s article on p 190 where he describes the all-encompassing reach of the commerce clause in the US Constitution].
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Congress wanted to regulate minimum price of interstate milk & therefore needed to fix the price of intrastate milk (otherwise could undercut, so had to regulate everybody).
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Stone CJ: necessary means appropriate; do not look at what is regulated intrastate but whether it has a sig affect on interstate commerce (“It is the effect upon interstate commerce or upon the exercise of the pwr to regulate it, not the source of the injury which is the criterion of Congressional pwr” p 193).
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control over intrastate milk was necessary & appropriate to make regulation of interstate commerce effective.
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Contrast this with Ansett where view is diff’nt (because in case above decided on eco nexus & not physical/safety factors).
To what extent can Cth regulate matters ancillary or subsequent to interstate or foreign trade & commerce? (issue relating to implied incidental pwr)
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ie, to what extent can Cth regulate production of commodities/goods to be exported?
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ambit of it is unclear; unsatisfactory because evidence is very limited & decided on narrow factual basis.
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O’Sullivan_v_Noarlunga_Meat'>O’Sullivan v Noarlunga Meat (1954)
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SA reg’ed slaughter of meat for export.
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Cth regs reg’ed matters concerning meat for export (reg 4B & 5).
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was there inconsistency betw’n these 2 (if so, Cth prevails).
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reg 4B provided that anyone who exported meat had to have a Cth licence.
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reg 5 (this was the ambiguous one causing the prob) said all premises used for slaughter of meat shall be registered.
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is it merely an ancillary prov to reg 4B (slaughter & export separate) or is it going beyond reg 4B & says may not slaughter until registered.
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on issue of regulating slaughter (potential inconsistency), HCA was divided 3:3 [NB: if HCA equally divided, decision of CJ or Senior Justice prevails if it is an original jurisdiction; if it is an appeal, decision of lower ct prevails].
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HCA was equally divided & it went onto appeal to PC about inconsistency issue & judgment of Fullagar J, Dixon CJ & Kitto J stood.
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Fullagar J considered whether s 51(i) empowered Cth to regulate slaughter of meat for export & said it does.
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Was it in core of pwr or incidental pwr? Fullagar J [relying on 1st case that recognised ‘implied incidental pwr’ in HCA, D’Emden v Pedder (1904)] said regs valid under implied incidental pwr to regulate prod’n of goods to be exported & within leg pwr conferred by s 51(i). The whole process was destined for export & all meat (goods) destined for export (does not matter if process is diff’nt) – see pp 194-5.
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2 issues in O’Sullivan: betw’n 2 valid laws & inconsistency.
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PC ruled on inconsistency point but on issue of valid law, had to rely on HCA because couldn’t get a certificate.
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If objectifiably recognised export process, Cth can regulate this. O’Sullivan concerned slaughter for export overseas. Would this apply to interstate? Yes.
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what if it is not an objectifiable export process? (ie, can Cth regulate prod’n of a commodity of which only a portion was to be exported?) Eg: if some meat was for export (interstate & foreign) & some for intrastate, because cannot distinguish should Cth regulate all?
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concerned chickens, most of which went intrastate; issue is whether Cth regs could apply?
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majority of HCA held that Cth regs did not purport to apply to such a sit’n (upon statutory construction of whether Cth sought to regulate such an activity, held that it was not intended).
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Owen J dissented: only way Cth could regulate the prod’n of commodity to export & ensure the quality of meat is okay is to regulate it all because could not separate it out & know which poultry goes where (either export or intrastate/home consumption – can’t tell) – therefore, whole operations should be governed by Cth regs [ie, regulate all meat prod’n, even if only a small % goes overseas].
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Redfern v Dunlop Rubber (1964)
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an Act said that any contract dealing with interstate commerce that was in restraint of trade (monopolisation) was void; in the contract was put an intrastate provision; q is what was effect of all this?
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HCA said Cth can nullify such a contract (ie, the Act applies to contracts combining overseas or interstate with intrastate matters).
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Owen J’s dissenting judgment in Swift is strengthened by the principle in this case, enunciated by Menzies J.
Note:
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What if Cth wanted to regulate all prod’n? No, it couldn’t.
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All goods for export. Could State regulate prod’n of those goods? Yes, States could (unless inconsistent with Cth law) because s 107 says that anything not given exclusively to Cth or if not taken away from State or if given to s 51(i) [which is not exclusive], the State can have.
WK 3.2
3/8/00
Revision
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Issue of Cth reg’n over prod’n.
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Industrial relations over factories dealing with prod’n going into interstate or foreign.
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US: Cth could regulate industrial relations over factories producing goods going interstate or foreign.
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Aust: not so broad view.
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In Huddart Parker v Cth (1931), Cth could provide that, in regard to interstate & foreign stevedoring, preference should be given to a particular union & it was generally accepted by HCA that Cth can regulate industrial relations of interstate & foreign on basis that it is incidental. In this case, the implied incidental pwr enabled s 51(i) to extend to the reg’n of employment relations betw’n stevedoring cos & waterside workers.
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O’Sullivan also fell within the implied incidental pwr as it was held that Cth could control physical conditions of factory so as to control quality of goods (also incl matters like health of workers, & ? as to inclusion of other industrial relations matters like wages).
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The effect of Swift (where only some of goods were exported as opposed to all) is really that Cth not permitted to regulate such a sit’n; Owen J was of view that have to regulate all prod’n because cannot separate out export from intrastate. In this case, however, ct was reluctant to give Cth more incidental pwrs with it.
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Cth can regulate a journey betw’n 2 states (Syd-Melb) at least for reward. There is no requirement that journey be in one unit/component (only one journey).
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Central Station (Syd) to Flinders Station (Melb) incl airport stops – yes.
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On principle of Ansett Case (1976), those getting off at airport, can’t do so.
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But bear in mind s 122 concerning Perth-Port Hedland-Darwin. Therefore, Central Station (Syd) to airport to Canberra, because territory (& not Melb) is okay & could provide for people to get off at airport & Central Station.
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Central Station (Syd) to airport to Melb – under Ansett Case (although questionable since a while ago) could not provide for people to get off at airport.
United States Commerce Clause
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Commerce clause/pwr could be useful basis for Bill of Rights.
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Early authority in 19th C gave the pwr a liberal interpretation.
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In 20th C, pwr has been given a mixed interpretation (results contradictory).
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Sup Ct from 1937 to 1995 gave it a liberal interpretation (increasing breadth).
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Congress set a quota on prod’n of wheat (idea was to reduce supply by increasing price).
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wheat was not going to interstate or foreign commerce but was going to feed family on farm (home consumption).
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Sup Ct said that Congress intended & could regulate it under commerce clause because the wheat grown on farm had substantial impact on interstate commerce:
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neg impact > wheat grown on farm would not go to market.
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if price was right, wheat grown for personal use would go on market (as surplus).
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intro of aggregate cumulation (small amounts could be cumulated into large amount based on size of country & can therefore have significant effect on interstate commerce).
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In Civil Rights Act 1964, Congress provided for the desegregation of places of public accommodation (like hotels & restaurants) that engaged in interstate trade & commerce.
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Heart of Atlanta Motel v United States (1964)
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downtown Atlanta hotel with a large interstate cliental.
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yes, Congress could regulate such a sit’n as the hotel was engaged in interstate commerce in 2 respects:
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a lot of travellers to hotel were from interstate.
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there was a lot of interstate trouble concerning segregation.
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if segregation the prob, then desegregation was the sol’n.
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Katzenbach v McClung (1964)
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principal ground for desegregation in this case was not because near interstate routes but because 46% of food purchased from outside Alabama.
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Black J said it was imp to not get too remote.
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ludicrous case.
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concerned exclusive priv club that engaged in swimming, boating & snack bar.
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was it engaged in interstate commerce? Yes because it would be unrealistic to assume that none of its visitors were from interstate (could come from nearby airforce base) & food (75% of it had interstate components) & entertainment (music from interstate) had connection to interstate commerce.
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Black J dissented, saying that connection was far too remote.
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Russell v United States (1985)
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concerned a federal arson statute which made it a federal offence to burn any building used in any activity concerning interstate or foreign commerce.
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q: did this apply to a rental building in suburban Chicago?
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held: rental real estate business is interstate commerce (by def’n).
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did the above statute apply to a priv apartment (not rental)?
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held: Congress did not intend it to apply to non-commercial properties & therefore avoided it (rather than say Cth could not do it).
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1st time since 1937 that Sup Ct had struck down any law for extending beyond commerce clause.
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fed law (Gun Free School Zones Act 1990) made it an offence to possess firearm within short distance from school.
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could it do so validly?
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Sup Ct said ‘no’ it could not (5:4):
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it did not regulate economic activity at all (mere possession of firearm is not an eco activity).
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Sup Ct did not purport to look to earlier decisions.
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there were no Congressional findings (& lack of finding did influence Sup Ct’s decision).
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minority regard decision as outrageous, contrary to long line of authority, arguing that school violence has a “substantial affect” on interstate commerce (violence > education > commerce).
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majority criticises this by saying then Cth should control family law (same reason).
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Thomas J (in maj in both Lopez & Morrison) said “substantial affect” test should be out.
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After Lopez, q was ‘is this the beginning of the end’?
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United States v Morrison (May 2000)
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concerned validity of fed law which provided a fed civil remedy for victims of gender-motivated violence.
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q: was leg’n of Congress under which she sues because raped valid?
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Sup Ct (5:4) said law invalid for same reasons as Lopez:
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because earlier cases were not questioned.
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rape was not an eco activity.
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held: not dealing with act that affects interstate commerce.
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minority: had made Congressional findings concerning impact of rape on interstate commerce (by rape possibly deterring her from interstate travel & involvement in interstate business/employment) & therefore law should have been upheld.
Summary:
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In light of Morrison, one has to put a little less weight on legislative findings.
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Critical test in US is that Congress can regulate anything that “substantially affects” interstate commerce provided that it is a commercial activity (& if it is purely non-commercial, ct will be weary).
Topic Summary – s 51(i):
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Cth can itself undertake interstate or foreign commerce; not confined to regulate priv activity – Airlines Case (1945).
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Transport, at least if for reward, & probably if not, is commerce – Airlines Cases.
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In considering ambit of s 51(i) & to what extent it extends to reg’n of intrastate commerce, q is whether reg’n of intrastate commerce is necessary to make effective interstate commerce.
Physical or at least safety factors can supply such a necessity, but economic factors can’t.
See Airlines of NSW (No 2) (1965) & Western Australian Airlines Case (Ansett) (1976).
Is this the current pos’n? The more conservative HCA today, as opposed to liberal one 5 yrs ago, would probably follow Dixon J & maintain a rigid physical, economic distinction. But this is diff’nt to the Masonic liberal view.
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Cth can prohibit the export or import of goods absolutely or on any condition it wishes regardless of motive, subject to s 92 (in regard to interstate commerce) – Huddart v Parker & Murphyores.
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s 51(i), like all pwrs, has an implied incidental pwr & under that Cth can regulate prod’n of goods to be exported - but unsettled q of what limitations are.
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where distinctly objectifiable export process, Cth can (O’Sullivan).
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but where not all destined for export (Swift), unclear whether Cth could regulate prod’n, unclear as to whether Owen J’s judgment would represent the current pos’n (Winterton believes it should).
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prod’n is not itself commerce (because obj not completed) but falls within implied incidental pwr.
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s 51(xx) enables a lot that cannot be done under s 51(i) to be done under s 51(xx) – eg: following Tasmanian Dam Case (1983) Cth can regulate prod’n of goods by trading corporation no matter what destination (interstate, intrastate, foreign).
Limitation of s 51(xx) is that it has to be a trading corporation, & not the issue of whether it is interstate, intrastate or foreign.
WK 4.1
7/8/00
Inconsistency
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There are more cases on this topic than any other because there are potentially so many practical sit’ns concerning its application (not because law in this area is incorrect).
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s 109 of the Const says that “When a law of a State is inconsistent with a law of the Cth, the latter shall prevail, & the former shall, to the extent of the inconsistency, be invalid”.
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ie, s 109 speaks of an inconsistent State law as being invalid (invalid means inoperative, not void). The significance of this is that if inconsistent, when Cth law is repealed, State law still exists & springs back.
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Wenn v A-G (Vic) (1948) held that State law on preference of re-employment of returned soldiers was inconsistent with Cth law. However, by the time of Butler v A-G (Vic) (1961), the Cth law had been repealed, so the State law was still on the books & sprang back.
3 Tests of Inconsistency
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There are 3 tests of inconsistency.
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The first 2 tests are called “egs of direct inconsistency”. See Mason J in Ansett v Wardley (1980).
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Impossibility of simultaneous obedience test
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Simultaneous obedience is impossible as there is a direct clash betw’n 2 laws – Daniell (1920).
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Denial of rights
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One law may create certain rights (rather than obligations) which are impaired, altered or detracted from by the other law. This widens the meaning of “inconsistent” & scope of s 109.
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See Dixon J in Victoria v Cth (the Kakariki Case) (1937): “When a State law, if valid, would alter, impair or detract from the operation of a law of the Cth Parl, then to that extent it is invalid”.
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See Colvin v Bradley Bros (1943).
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Indirect inconsistency – “Covering the field test”
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If the Cth intends to cover the field (expressly or impliedly), then there will be an inconsistency with any State law on that field.
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See Clyde Engineering v Cowburn (1926).
Cases
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Clyde Engineering v Cowburn (1926)
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this case est very clearly the “covering the field” test & was enunciated by Isaacs J.
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NSW law provided for 44 hr working week & Cth award provided for 48 hr working week.
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HCA held that there was inconsistency on both 2nd & 3rd tests. On 2nd test because one law was taking away a right given by the other (44 vs 48). On 3rd test, where Cth intends to cover the field, then any State law on the field (even if same words) becomes inoperative. Why? Because Cth is saying this is the law & this shall be the only law on the topic.
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Cth can cover the field expressly or impliedly (nowadays it is most likely that it is express).
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Colvin v Bradley Bros (1943)
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this case is a classic 2nd test inconsistency.
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State law prohibited employment of women in certain industry (milling machines) & Cth allowed it.
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there was no 1st test inconsistency because did not have to employ women [if obligation rather than rights, like “must” rather than “may”, there is inconsistency via 1st test].
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one gave right to women employment & other took it away.
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this case dealt with a potential inconsistency betw’n a Cth award & a State law.
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many inconsistency cases (2/3) arise in case of industrial relations & many of them involve dispute betw’n Cth award of IRC & State law.
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Cth does not have direct pwr over industrial relations [s 51(xxxv) allows for setting up of conciliation & arbitration body to resolve industrial disputes & issue awards – quasi-judicial awards (exercise of leg, admin pwr)]. These awards can cover broad topics & hence increase chance of inconsistency.
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Dixon J: under the covering the field test, inconsistency depends upon whether or not Cth intended the Cth law to “completely, exhaustively, or exclusively” state the law in the field covered by or on the subj matter reg’ed by that law.
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If you have a potential inconsistency betw’n Cth award of IRC & State law, do you have a potential inconsistency betw’n 2 laws in relation to s 109 (ie, is IRC award a law? No). Then, if not law, what is the prob? The awards are given force of law thro statute (ie, behind the award stands the Act & it is this Cth Act that gives the award legal force vs State law, and therefore 2 s 109 laws).
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It may be that practical effect of saying you could have inconsistency betw’n Cth award & State law is diff’nt to saying inconsistency betw’n 2 Acts (because potential area of Cth awards is huge).
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If you deal with clash betw’n 2 Acts (Cth law & State law), then topic of Cth law would not matter.
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If clash betw’n Fed award & State law, only 3rd test inconsistency will occur where State law deals with same narrow topic as Cth award does.
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In this case, there was State law inconsistency because dealing with same narrow industrial relations topic as Cth.
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ie, where there is a clash betw’n 2 laws, it probably does not matter if not on same topic (but need same field) – eg: one concerns animals, the other concerns industrial relations (if both deal with harm to sheep, then probably 3rd test inconsistency).
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ie, where there is a clash betw’n Fed award & State law, take narrow view & say State law is only inconsistent if it deals with same narrow industrial relations topic as award deals with.
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potential inconsistency betw’n Cth award & State law.
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Cth award concerned metal industry & allowed for summary dismissal of employees.
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State law said that before summary dismissal of an employee, you needed to see Registrar & go thro’ steps (ie, summary dismissal not allowed).
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Was there inconsistency? HCA said ‘yes’ because of denial of rights & because covering the field (both dealing with same narrow industrial relations topic).
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Collins v Charles Marshall (1955)
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this case maintains Dixon J’s approach.
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potential inconsistency betw’n a Cth award (Metal Trades award) which provided for all usual industrial relations aspects (like annual leave) but did not mention long service leave, & Vict Act which provided for long service leave.
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both deal with industrial relations.
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no direct inconsistency because one is silent.
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no inconsistency because although both dealing with industrial relations, Cth Act did not intend to cover the issue of long service leave.
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Note: T A Robinson v Haylor (1957) said that to incl long service leave, Cth would have to expressly state it in the award (p 134).
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potential inconsistency betw’n Fed Pilot’s Act which dealt with hiring & firing of pilots, & Vict’s Equal Opportunity Act that prohibited sexual discrimination in employment or dismissal.
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Equal Opp Board found that Ansett refused to hire her on basis of her sex, & ordered Ansett to employ her. Ansett challenged this, arguing inconsistency.
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HCA said there was no inconsistency & Wardley successful (3:2).
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There is in a sense a hybrid betw’n an express & implied intention to cover the field.
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Eg: if Cth Act appears to assume the continued existence of State law or expressly states that it is not intending to cover the field & keep State law on the field, Cth is not covering the field. There can also be an express allusion to State law which means State law continues or Cth can also impliedly indicate that it is not intending to cover the field (eg: a sparse reg’n on the field). [See Mason J on p 140]
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Where gen law is in an area of civil rights, ct will look to subj matter of 2 laws & lean against an interpretation that Cth intended to cover the field.
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Mason J said that there was an assumed existence of State law & therefore Cth did not intend to cover the field.
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O’Sullivan v Noarlunga Meat (1954)
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HCA split as to whether Cth is dealing with same topic.
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State > slaughter; Cth > export.
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HCA maj:
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There was 2nd test inconsistency. Although drafting of reg 5 of Cth was bad (“No person may slaughter meat for export unless place is reg’ed”), HCA implied that to mean that if you did register, you can export. This is in contradiction with State law that said you must register with us as well (to export you need to be reg’ed). This implied reading results in inconsistency.
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There was also inconsistency on 3rd test. Fullagar J said the Cth impliedly covered the field because of the detailed set of requirements that had to be complied with before reg’n of place for slaughter of meat for export (materials, etc).
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Therefore, both 2nd & 3rd tests inconsistency (which is common in licensing sit’ns) – see Raptis v SA (1978) in which HCA said there was 2nd & 3rd test inconsistency concerning a fishing licence.
Note:
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Airlines of NSW (No 2) (1965)
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also concerned inconsistency.
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regs 198 & 199 were held valid, 200B invalid.
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were regs 198 & 199 inconsistent with State law?
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Cth’s pwr over intrastate commerce was a rather tenuous field. Cth has pwr over safety aspects of intrastate commerce (to make interstate & foreign commerce effective) & State law dealt with intrastate air navigation (in the form of character, suitability & fitness of licence applicants).
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HCA said laws dealt with diff’nt subj matters, & therefore, no inconsistency issue arose.
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HCA said if there is a clear intention by Cth to cover the field, then there is inconsistency, otherwise not [ct leans against it covering the field if Cth does not make it clear].
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