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In addition to New York and Michigan, six other states permit direct shipment by in-state wineries while restricting it for others. They are Connecticut, Massachusetts, Florida, Ohio, Indiana and Vermont. Thirteen others are known as reciprocity states, which permit direct sales only from wineries in states that in turn permit out-of-state direct shipments.

Under the court's analysis, which lamented "the current patchwork of laws" that Justice Kennedy said was "essentially the product of an ongoing, low-level trade war," those laws are also now invalid. The reciprocity states are California, Colorado, Hawaii, Idaho, Illinois, Idaho, Minnesota, Missouri, New Mexico, Oregon, Washington, Wisconsin and West Virginia.

An additional 15 states currently prohibit all direct-to-consumer wine shipments. They are Alabama, Arkansas, Delaware, Kansas, Kentucky, Maine, Maryland, Mississippi, Montana, New Jersey, Oklahoma, Pennsylvania, South Dakota, Tennessee and Utah.