## Facts

- Two Puerto Rico nonprofit organizations involved in cockfighting-related activities challenged a 2018 federal statutory amendment extending the Animal Welfare Act’s animal-fighting prohibition to all U.S. jurisdictions, including territories.
- The amendment criminalized knowingly sponsoring or exhibiting an animal in an animal fighting venture, making cockfighting illegal in Puerto Rico as of December 20, 2019.
- Plaintiffs sued the United States, federal agencies (USDA and DOJ), and federal officials in their official capacities, seeking declaratory and injunctive relief barring enforcement in Puerto Rico.
- The cases were consolidated in the District of Puerto Rico.
- The parties filed cross-motions for summary judgment.

## Issues

1. Whether Congress had authority under the Territorial Clause and/or Commerce Clause to apply the Animal Welfare Act’s animal-fighting ban to Puerto Rico.
2. Whether the extension of the ban violated the Tenth Amendment by intruding on Puerto Rico’s asserted local police powers.
3. Whether the ban violated due process by eliminating a regulated local industry and tradition.
4. Whether the ban violated the First Amendment by burdening expressive conduct or association related to cockfighting.

## Decision

- The court granted the United States’ cross-motion for summary judgment and denied plaintiffs’ motion.
- The court held that Congress acted within its powers under the Territorial Clause and the Commerce Clause in extending the animal-fighting prohibition to Puerto Rico.
- The court rejected plaintiffs’ Tenth Amendment challenge because the statute directly regulates private conduct and does not commandeer territorial officials.
- The court rejected due process claims, holding there is no fundamental right to engage in cockfighting and the statute satisfied rational basis review.
- The court rejected First Amendment claims, concluding the law regulates conduct (animal fighting ventures), is content-neutral, and any incidental effect on expression or association did not render it unconstitutional.

## Legal Principles

- Congress may legislate for U.S. territories under the Territorial Clause and may apply federal statutes to territories as it does to states, subject to constitutional limits.
- Under the Commerce Clause, Congress may prohibit conduct substantially related to interstate or foreign commerce and may close jurisdictional loopholes to protect a nationwide regulatory scheme.
- The Tenth Amendment does not invalidate a federal statute enacted pursuant to an enumerated power; a direct federal prohibition on private conduct does not constitute unconstitutional commandeering.
- Substantive due process protects only fundamental rights; absent a fundamental right, economic and social legislation is reviewed for a rational relationship to a legitimate governmental interest.
- Laws targeting conduct rather than speech, and aimed at content-neutral objectives such as animal welfare and commerce, generally do not violate the First Amendment merely because they incidentally affect association or cultural practices.

## Conclusion

The District of Puerto Rico upheld the 2018 federal extension of the Animal Welfare Act’s animal-fighting ban to Puerto Rico, concluding Congress validly exercised Territorial Clause and Commerce Clause powers and that the statute violated neither the Tenth Amendment, due process, nor the First Amendment.


Club Gallístico de Puerto Rico, Inc. v. United States, 414 F. Supp. 3d 191 (D.P.R. 2019)