## Facts

- Humboldt County livestock producers planned to construct and operate “large livestock confinement feeding operations” in the county.
- In October 1996, the Humboldt County Board of Supervisors adopted four ordinances regulating large livestock confinement facilities:
  - Ordinance 22 required a county “notice of construction or operation” before construction or operation and mandated an application with facility plans and manure management information.
  - Ordinance 23 imposed financial security requirements intended to ensure funds for closure, cleanup, and damages.
  - Ordinance 24 imposed local groundwater-protection requirements affecting siting, design, and operation.
  - Ordinance 25 imposed local controls on toxic air emissions and related operating restrictions.
- Producers filed consolidated actions seeking declaratory and injunctive relief, arguing the ordinances were preempted by Iowa statutes and state agency regulation of confinement feeding operations.
- The district court upheld most of the ordinances; the producers appealed, and the county did not appeal adverse portions.

## Issues

1. Whether Iowa’s statutory and regulatory scheme for livestock confinement operations preempted Humboldt County’s ordinances under Iowa home rule limits.
2. Whether the ordinances were “inconsistent with” state law because they conflicted with, or added conditions beyond, the state regulatory framework.

## Decision

- The Supreme Court of Iowa reversed the district court and remanded for entry of summary judgment for the producers.
- The court held the legislature had preempted county authority to regulate livestock confinement operations through a comprehensive state scheme.
- The court concluded the ordinances were invalid because they imposed additional local permitting, financial assurance, groundwater, and air-emission requirements that conflicted with state law and administration.

## Legal Principles

- County home rule authority is limited by the requirement that local enactments not be “inconsistent with” state law.
- Preemption may be found when the legislature expressly restricts local regulation or when a pervasive and comprehensive statutory scheme implies an intent to occupy the field.
- A local ordinance is inconsistent with state law when it conflicts with state statutes or regulations, is irreconcilable with them, or effectively prohibits what state law permits.
- Where the state has established comprehensive regulation of livestock confinement operations, counties may not add parallel approval mechanisms or additional substantive requirements in the same regulatory area.

## Conclusion

The Iowa Supreme Court invalidated Humboldt County’s ordinances regulating large livestock confinement feeding operations because Iowa’s comprehensive state regulatory scheme preempted local regulation, and the ordinances’ added permitting and environmental requirements conflicted with state law.


Goodell v. Humboldt County, 575 N.W.2d 486 (Iowa 1998)