Alexis Bailly Vineyard, Inc. v. John Harrington, 931 F.3d 774

Minnesota’s Farm Wineries Act creates a special farm-winery license permitting direct sales to retailers and consumers but requires a farm winery to produce wine “with a majority of the ingredients grown or produced in Minnesota.”
Farm winery licensees pay $50/year, must produce under 75,000 gallons, and be located on agricultural land; an affidavit exception allows temporary use of out-of-state ingredients if Minnesota ingredients are unavailable.
Alexis Bailly Vineyard, Inc. and The Next Chapter Winery, LLC (collectively, Farm Wineries) hold farm-winery licenses and want to expand production using out-of-state ingredients, but contend the in-state majority requirement blocks that expansion.
The Farm Wineries brought a pre-enforcement dormant Commerce Clause challenge seeking declaratory relief that the in-state requirement is unconstitutional.
The district court granted summary judgment to the Commissioner for lack of standing, reasoning the wineries’ injuries resulted from their voluntary choice to operate under the farm-winery license rather than as manufacturers.
The Eighth Circuit reversed, holding the Farm Wineries have standing and remanded for the district court to address the constitutional merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing — injury in fact	Farm Wineries intend to expand using out-of-state ingredients; the statute currently bars that, creating imminent, concrete injury	No imminent injury; affidavits and lack of past enforcement show threat of prosecution not credible	Injury in fact exists: they have a present intention proscribed by statute and face a credible threat of enforcement
Standing — traceability	Injuries flow from the statute’s in-state majority requirement that conditions the farm-winery license	Harms are self-inflicted by choosing the farm-winery license instead of a manufacturer license; thus not traceable to statute	Harms are fairly traceable; Commissioner has authority to enforce the provision and statute conditions the license
Standing — redressability	A declaratory judgment removing the in-state requirement would allow expansion and redress harms	Removal of the requirement would not redress self-chosen licensing framework	Redressability satisfied: ruling would remove the asserted constraint and aid plaintiffs
Merits (dormant Commerce Clause)	The in-state preference discriminates against out-of-state suppliers in violation of the dormant Commerce Clause	State interest in regulating alcohol under Twenty-first Amendment and promoting local industry justifies the rule	Court declined to decide on the merits and remanded for district court consideration

Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing framework for causation and redressability)
Susan B. Anthony List v. Driehaus, 573 U.S. 149 (pre-enforcement standing rules)
MedImmune, Inc. v. Genentech, Inc., 549 U.S. 118 (pre-enforcement challenge principles)
Clapper v. Amnesty International USA, 568 U.S. 398 (limits on speculative injury allegations)
Granholm v. Heald, 544 U.S. 460 (state licensing and discriminatory restrictions on interstate wine sales)
Tenn. Wine & Spirits Retailers Ass’n v. Thomas, 139 S. Ct. 2449 (Twenty-first Amendment does not permit protectionist discrimination)
S.D. Farm Bureau, Inc. v. Hazeltine, 340 F.3d 583 (dormant Commerce Clause economic-injury standing precedent)
North Dakota v. Heydinger, 825 F.3d 912 (pre-enforcement challenge where statute’s text supports credible threat of enforcement)