The U.S. Supreme Court case Fort Gratiot Sanitary Landfill, Inc. v. Michigan Department of Natural Resources et al., 1991 dealt with the issue of waste disposal across state lines and whether a state could restrict or prohibit out-of-state waste from being disposed in its landfills. The plaintiff, Fort Gratiot Sanitary Landfill, Inc., challenged a Michigan law that limited the amount of solid waste it could accept from outside the county where it was located to 30% of total volume received annually. The company argued this violated the Commerce Clause by discriminating against interstate commerce as they were unable to receive and dispose wastes coming from other states freely. The Supreme Court ruled in favor of Fort Gratiot Sanitary Landfill, stating that under the Commerce Clause, states cannot discriminate against or burden interstate commerce unless authorized by Congress - which had not occurred here. Therefore, Michigan's law limiting out-of-county trash imports was unconstitutional because it interfered with free trade among states.

In the dissenting opinion for Fort Gratiot Sanitary Landfill, Inc. v. Michigan Department of Natural Resources et al., Justice Blackmun argued that states should have the right to regulate waste disposal within their borders without interference from Congress or other states. He believed that this case was not about interstate commerce but rather about a state's ability to protect its environment and public health by controlling how much waste it accepts and where it goes. The majority decision, he felt, undermined these important state powers and could lead to negative consequences such as overburdened landfills and environmental damage. Furthermore, he disagreed with the majority's interpretation of relevant federal laws on waste management which they used in reaching their decision.