National Meat Assn. v. Harris
132 S. Ct. 965
| SCOTUS | 2012Background
- FMIA regulates slaughterhouses for meat safety and humane handling; FSIS administers it with extensive live-animal and post-mortem inspection rules.
- California amended its penal code to §599f (2008) prohibiting buying, processing, or holding nonambulatory animals at slaughterhouses, with penalties; this law targets slaughterhouse premises and operations.
- FMIA §678 preempts any state requirement that is additional or different from FMIA for premises/facilities/operations, even if non-conflicting.
- NMA sued to enjoin §599f as preempted; district court granted injunction, Ninth Circuit reversed, and Supreme Court granted certiorari.
- The Court held that FMIA expressly preempts §599f as applied to federally inspected swine slaughterhouses, effectively displacing the California statute on the premises/operations of slaughterhouses.
- The decision discusses that FMIA governs humane handling and prevents states from imposing different regulatory schemes on nonambulatory pigs during production.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does FMIA express preemption apply to §599f as applied to swine slaughterhouses? | NMA argues FMIA §§678 doesn't preempt; state regulation not within FMIA scope. | California/Humane Society argues §599f affects slaughterhouse operations and falls within FMIA scope. | Yes; FMIA preempts §599f as applied. |
| Do §599f(b)-(c) impose additional/different requirements beyond FMIA? | NMA contends §599f imposes new handling/processing rules not in FMIA. | State claims §599f regulates humane treatment within FMIA scope. | Yes; §599f imposes different requirements and is preempted. |
| Does §599f(a) on purchasing nonambulatory pigs fall outside FMIA due to off-site purchases? | NMA suggests off-site purchases are outside slaughterhouse scope and not preempted. | FMIA focuses on premises/operations; off-site regulation could be separate, but is still within FMIA’s reach. | Preemption applies to on-site purchases; controlling holding that off-site purchases do not escape FMIA scope. |
Key Cases Cited
- Pittsburgh Melting Co. v. Totten, 248 U.S. 1 (1918) (early preemption/background on misaligned state and federal schemes)
- Bates v. Dow Agrosciences, LLC, 544 U.S. 431 (2005) (federal-preemption limits: ‘in addition to or different’ not allowed)
- Engine Mfrs. Assn. v. South Coast Air Quality Management Dist., 541 U.S. 246 (2004) (textbook preemption principle; design philosophy for federal/state regulation)
- Cavel International, Inc. v. Madigan, 500 F.3d 551 (7th Cir. 2007) (categorical bans on slaughtering certain animals discussed in preemption context)
- Empacadora de Carnes de Fresnillo, S. A. de C.V. v. Curry, 476 F.3d 326 (5th Cir. 2007) (foreign slaughter restrictions and FMIA scope cited in preemption considerations)
- National Meat Association v. Brown, 599 F.3d 1093 (9th Cir. 2010) ( Ninth Circuit preemption discussion; context for FMIA scope over nonambulatory pigs)