Law School Case Brief
Nat'l Meat Ass'n v. Harris - 565 U.S. 452, 132 S. Ct. 965 (2012)
The Federal Meat Inspection Act's (FMIA's), 21 U.S.C.S. §§ 601 et seq., preemption clause sweeps widely--and in so doing, blocks application of Cal. Penal Code § 599f. The clause prevents a State from imposing any additional or different -- even if nonconflicting -- requirements that fall within the scope of the FMIA and concern a slaughterhouse's facilities or operations. At every turn, § 599f imposes additional or different requirements on swine slaughterhouses. It compels them to deal with nonambulatory pigs on their premises in ways that the FMIA and regulations that implement the FMIA do not. In essence, California's statute substitutes a new regulatory scheme for the one the U.S. Department of Agriculture's Food Safety and Inspection Service uses.
After the Humane Society of the United States released a video showing workers at a slaughterhouse in California dragging, kicking, and electroshocking sick and disabled cows in an effort to move them, the State of California enacted Cal. Penal Code § 599f to strengthen a preexisting statute governing the treatment of nonambulatory animals and to apply that statute to slaughterhouses regulated under the Federal Meat Inspection Act (FMIA or Act). Petitioner National Meat Association (NMA), a trade association that represented meatpackers and processors, including operators of swine slaughterhouses, sued to enjoin enforcement of § 599f against swine slaughterhouses, arguing that § 599f was preempted by the FMIA. The District Court agreed, and granted the NMA a preliminary injunction. The Ninth Circuit reversed, holding that §599f is not preempted because it regulates only “the kind of animal that may be slaughtered,” not the inspection or slaughtering process itself.
Was § 599f preempted by the FMIA?
TheUnited States Supreme Court found that the California statute was preempted by the FMIA. 21 U.S.C.S. § 678 prevented the States from imposing additional or different--even if nonconflicting--requirements that fell within the FMIA's scope and concerned slaughterhouse facilities or operations, and § 599f imposed additional or different requirements on swine slaughterhouses. Slaughterhouses in California could take one course of action in handling nonambulatory pigs under the FMIA and its implementing regulations, but had to take another course of action under § 599f.
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