Hettinga v. United States
400 U.S. App. D.C. 218
| D.C. Cir. | 2012Background
- Hettinga appeal district court's dismissal of facial constitutional challenges to MREA Subsections M and N.
- MREA amended AMAA to apply pricing/pooling to certain large producer-handlers and to those selling milk across state lines from regulated areas.
- Sarah Farms (Arizona) and GH Dairy (Arizona) were the Hettingas’ businesses affected by the challenged provisions.
- USDA Rule amended exemptions for large producer-handlers; MREA structured open-ended applicability rather than identifying specific individuals.
- Court reviews Rule 12(b)(6) dismissal de novo to assess facial plausibility of constitutional claims; district court held no Bill of Attainder, denied equal protection and due process challenges.
- Hettingas dismissed their case after MREA was enacted, arguing it illegally punished them and violated due process; court affirmed dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MREA is a bill of attainder. | Hettingas contend MREA singles them out for punishment. | Defendants argue MREA regulates future conduct with open-ended applicability. | Not a bill of attainder; lacks specificity. |
| Whether MREA satisfies equal protection under rational-basis review. | Hettingas claim disparate treatment cannot be rationalized. | Law rationally aims to maintain orderly milk markets and competitive balance. | Rational basis upheld; no equal protection violation. |
| Whether MREA violates due process by foreclosing judicial review. | MREA mooted pending claims and impeded review of USDA Rule. | Legislation moots claims without triggering due process concerns; no liberty/property interest implicated. | No due process violation. |
| Whether the district court abused discretion by denying supplemental pleading. | Hettingas sought to amend based on political campaign materials. | Proposed amendments would be futile and fail to state new viable claims. | District court did not abuse discretion; amendment denied. |
Key Cases Cited
- Nebbia v. New York, 291 U.S. 502 (Supreme Court 1934) (economic regulation given broad latitude under rational basis)
- BellSouth Corp. v. FCC, 144 F.3d 58 (D.C. Cir. 1998) (open-ended classifications are not per se unconstitutional)
- Nixon v. Administrator of General Services, 433 U.S. 425 (Supreme Court 1977) (class of one; open-ended applicability may avoid attainder)
- Foretich v. United States, 351 F.3d 1198 (D.C. Cir. 2003) (definition of bill of attainder requires specify-punishment-trial)
- Selective Serv. Sys. v. Minn. Pub. Interest Research Grp., 468 U.S. 841 (Supreme Court 1984) (attaches punishment only with specificity and intent)
- Ashcroft v. Iqbal, 556 U.S. 662 (Supreme Court 2009) (plausibility standard in pleading after Twombly)
- Beach Communications, Inc. v. FCC, 508 U.S. 307 (Supreme Court 1993) (strong presumption of validity for economic regulation; rational basis sufficient)
- Dumaguin v. Sec'y of Health and Human Servs., 28 F.3d 1218 (D.C. Cir. 1994) (pleading standard for equal protection claims)
- Lamers Dairy, Inc. v. Dep't of Agric., 379 F.3d 466 (7th Cir. 2004) (economic regulation may be rationally related to public goals)
- Shamrock Farms Co. v. Veneman, 146 F.3d 1177 (9th Cir. 1998) (rational basis review in agricultural regulation)