erposed its veto on
the basis of Oklahoma _v._ Kansas Natural Gas Co.[971]

STATE CONSERVATION AND EMBARGO MEASURES: THE SHRIMP CASES

Meantime, Geer _v._ Connecticut has been somewhat overcast by subsequent
rulings. In a case, decided in 1928, it was held that a Louisiana
statute which permitted the shipment of shrimp taken in the tidal waters
of Louisiana marshes only if the heads and hulls have been previously
removed was unconstitutional.[972] Distinguishing Geer _v._ Connecticut
the Court said: "As the representative of its people, the State might
have retained the shrimp for [local] consumption and use therein." But
the object of the Louisiana statute was in direct opposition to the
conservation of a local food supply. Its object was to favor the canning
of shrimp for the interstate market. "* * * by permitting its shrimp to
be taken and all the products thereof to be shipped and sold in
interstate commerce, the State necessarily releases its hold and, as to
the shrimp so taken, definitely terminates its control. * * * And those
taking the shrimp under the authority of the act necessarily thereby
become entitled to the rights of private ownership and the protection of
the commerce clause."[973] On the same reasoning a South Carolina
statute which required that owners of shrimp boats, fishing in the
marine waters off the coast of the State, dock at a State port and
unload, pack and stamp their catch with a tax stamp before shipping or
transporting it to another State, was pronounced void in 1948.[974]
However, a California statute which restricted the processing of fish,
both that taken in the waters of the State and that brought into the
State in a fresh condition, was found by the Court to be purely a food
conservation measure, and hence valid.[975] The application of the act
to fish brought from outside was held to be justified "by rendering
evasion of it less easy."[976]

Concurrent Federal and State Legislation

THE GENERAL ISSUE

Since the turn of the century federal legislation under the commerce
clause has penetrated more and more deeply into areas once occupied
exclusively by the police power of the States. The result has been that
State laws have come under increasingly frequent attack as being
incompatible with acts of Congress operating in the same general field.
The Court's decisions resolving such alleged conflicts fall into three
groups: _first_, those which follow Webster's theory, advanc