National Meat Assn. v. Harris
Headline: Federal meat inspection law preempts California’s ban on handling, euthanizing, and selling meat from nonambulatory pigs, blocking state rules and leaving FMIA rules in charge at regulated slaughterhouses.
Holding:
- California may not apply §599f to slaughterhouses covered by the federal inspection law.
- Slaughterhouses can follow federal FMIA rules for nonambulatory pigs, including inspection and post‑mortem decisions.
- Criminal penalties under §599f cannot be imposed when they conflict with FMIA requirements.
Summary
Background
A trade association representing meatpackers and swine slaughterhouses sued after California revised its law about nonambulatory animals. The state law (§599f) bars slaughterhouses from buying or receiving nonambulatory animals, requires immediate humane euthanasia of such animals on the premises, and forbids processing or selling meat from them. The change followed a 2008 undercover video that showed mistreatment of livestock at a slaughterhouse. The Federal Meat Inspection Act (FMIA) and its agency, the FSIS, already regulate inspection, humane handling, ante‑mortem and post‑mortem review, and permit processing noncondemned nonambulatory animals subject to inspection. The Ninth Circuit had allowed California’s law to stand.
Reasoning
The Court asked whether the FMIA’s express preemption clause prevents states from imposing different or additional requirements on a slaughterhouse’s premises, facilities, or operations. The Justices concluded that California’s law does just that: it directs slaughterhouses to refuse receipt, to euthanize on site, or to bar processing and sale in ways the FMIA and FSIS do not. Because the FMIA covers handling from delivery through post‑mortem inspection and includes humane‑handling rules, the Court found the state provisions conflicted with the federal regulatory scheme and were preempted.
Real world impact
As a result, California cannot enforce the challenged portions of §599f against slaughterhouses subject to the FMIA; federal rules control how nonambulatory pigs are inspected, treated, and processed. The decision returns regulatory authority over day‑to‑day slaughterhouse practices to the federal system, though states retain some room to enforce general animal‑cruelty laws that are consistent with the FMIA. The case was reversed and remanded to the lower courts.
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