In the 1983 case Michigan Canners & Freezers Association, Inc., et al. v. Agricultural Marketing and Bargaining Board et al., the U.S Supreme Court ruled on a dispute involving agricultural labor laws in Michigan. The state's legislature had passed an act that required processors of farm products to negotiate with producers' associations over prices and other terms of trade, which was challenged by canners and freezers who claimed it violated their rights under the Commerce Clause and Equal Protection Clause of the Constitution. The court held that while states have broad power to regulate local aspects of interstate commerce, they cannot discriminate against or excessively burden such commerce unless there is no other means to achieve an important state purpose. In this case, however, the court found that less restrictive alternatives were available for achieving Michigan’s goal of protecting its farmers from unfair practices by large corporate buyers.

In the dissenting opinion for Michigan Canners & Freezers Association, Inc., et al. v. Agricultural Marketing and Bargaining Board et al., Justice O'Connor argued that the majority's decision was inconsistent with previous Supreme Court rulings on similar issues of commerce clause jurisprudence. She contended that by upholding a state statute which allowed an agricultural marketing board to set prices for produce sold within its borders, even if it affected interstate commerce, the court had effectively sanctioned protectionist legislation favoring local interests over national ones. This contradicted earlier decisions where such laws were struck down as unconstitutional barriers to free trade among states. Furthermore, she disagreed with the majority's view that Congress' silence on this matter implied consent to state regulation; instead asserting it should be interpreted as non-endorsement of such practices due to potential conflicts with federal policies promoting competitive markets.