In a decision that is likely to be emulated in other states, the Supreme Court of New Jersey has recently rejected Commerce Clause challenges to that state's ban on the in-state dumping of solid waste originating outside New Jersey. The unanimous opinion in Hackensack Meadowlands Development Commission v. Municipal Sanitary Landfill Authority¹ found that state erection of such barriers was an undeniably legitimate police power action, and that the beneficial postponement of sacrificing increasingly scarce wetlands to landfill operators far outweighed any corresponding hindrance to interstate transportation of non-recyclable solid wastes. Following in the wake of notably unsuccessful attempts under the Commerce Clause to overturn bans on nonreturnable bottles,² phosphate detergents,³ and marine oil spillage,⁴ the decision may ultimately lead to enactment of similar measures in other states,⁵ a development that would only accelerate the balkanization of environmental management. On the other hand, the case serves as a bellwhether for the tough solid waste-related land-use decisions that may soon become the national norm.