Facts
- The Federal Meat Inspection Act (FMIA) regulates slaughterhouse operations, including meat inspection and humane handling of livestock, through detailed USDA regulations.
- Under federal regulations, every animal receives ante-mortem inspection; nonambulatory animals may be classified as “U.S. Condemned” (excluded from food production) or “U.S. Suspect” (segregated, monitored, and potentially slaughtered separately), followed by post-mortem inspection to determine permissible use.
- The FMIA contains an express preemption clause barring state requirements, within FMIA’s scope and relating to slaughterhouse “premises, facilities and operations,” that are “in addition to, or different than” federal requirements.
- California Penal Code § 599f (as amended in 2008) prohibited slaughterhouses from buying, selling, or receiving nonambulatory animals; prohibited processing or selling meat from such animals for human consumption; and required immediate humane euthanasia of any nonambulatory animal.
- The National Meat Association sued to enjoin enforcement of § 599f against federally inspected swine slaughterhouses, alleging FMIA preemption.
- The district court granted a preliminary injunction; the Ninth Circuit reversed, viewing § 599f as regulating which animals may be slaughtered rather than slaughterhouse operations.
Issues
- Whether the FMIA’s express preemption clause, 21 U.S.C. § 678, preempts California Penal Code § 599f as applied to federally inspected swine slaughterhouses.
- Whether a state may require immediate euthanasia and prohibit slaughter or sale of meat from nonambulatory animals when federal regulations permit inspection-based treatment and potential processing.
Decision
- The Supreme Court unanimously reversed the Ninth Circuit and remanded.
- The Court held that the FMIA expressly preempts § 599f’s application to federally inspected swine slaughterhouses.
- The Court concluded § 599f regulates slaughterhouse “operations” and imposes requirements “in addition to, or different than” federal rules governing the handling, inspection, and potential processing of nonambulatory animals.
Legal Principles
- The FMIA’s express preemption clause is broad and bars state requirements within FMIA’s scope that relate to slaughterhouse “premises, facilities and operations” and that differ from, or add to, federal requirements.
- State measures directed at how federally inspected slaughterhouses handle particular animals (including nonambulatory livestock) regulate “operations,” even if framed as regulating which animals may be slaughtered.
- When federal law provides an inspection-based pathway that can permit processing after classification and post-mortem review, a state may not eliminate that pathway for federally inspected plants by imposing categorical prohibitions.
- No exception to FMIA preemption exists merely because a state rule is motivated by humane-treatment or animal-welfare concerns, where the federal scheme also regulates humane handling.
Conclusion
The Court held that California’s nonambulatory-animal statute, as applied to federally inspected swine slaughterhouses, was expressly preempted because it imposed operational requirements different from the FMIA’s comprehensive inspection and humane-handling regime.