Abstract
Section II of this article will lay out the history of wine distribution, beginning with the rise of the three-tier distribution system. Next, it discusses the modern growth of e-commerce and the events leading to the Granholm decision. Section III will explain the Granholm ruling and demonstrate how lower federal courts inconsistently interpreted Granholm outside the production tier. Finally, Section IV will explain the problems created by inconsistent application of Granholm, analyze the reasoning and intent of the Court's opinion, note applicable political considerations, and analyze the dormant Commerce Clause in order to show that the ruling should be extended to all distribution tiers, rather than applying exclusively to the first tier.
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