## Facts

- Several states sued California officials to block enforcement of California laws regulating the confinement conditions for egg-laying hens and requiring that shell eggs sold in California meet those standards, even if produced out of state.
- The states alleged the sales requirement would force their egg producers either to retrofit facilities at substantial cost to comply or to stop selling into the California market.
- The states further alleged resulting economic effects, including loss of jobs and tax revenue in their states and higher egg prices for their citizens.
- The states asserted they sued as parens patriae on behalf of their citizens (including egg producers and consumers), contending the California scheme was protectionist and unlawfully affected out-of-state production choices.
- California moved to dismiss on the ground that the plaintiff states lacked Article III standing, including parens patriae standing.

## Issues

1. Whether the plaintiff states had Article III standing—particularly parens patriae standing—to challenge California’s egg-sales requirements on behalf of their citizens and egg producers.
2. If standing existed, whether the challenged requirements violated the Commerce Clause (including dormant Commerce Clause limits) or were preempted under the Supremacy Clause.

## Decision

- The court granted California’s motion to dismiss for lack of Article III standing.
- The court held the plaintiff states failed to plead an injury to a quasi-sovereign interest sufficient to support parens patriae standing.
- The court found the alleged injuries were primarily economic harms to a discrete group of private businesses (egg producers) and that asserted consumer harms were indirect and uncertain.
- The court dismissed the action with prejudice and did not reach the Commerce Clause or Supremacy Clause merits.

## Legal Principles

- A state asserting parens patriae standing must allege injury to a quasi-sovereign interest that is distinct from the interests of particular private parties and that affects a sufficiently substantial segment of the state’s population.
- Alleged economic injuries concentrated in a specific industry generally do not constitute a quasi-sovereign injury for parens patriae purposes.
- Speculative, contingent downstream economic effects (such as predicted price changes dependent on market behavior) are insufficient to establish Article III injury.
- When a plaintiff lacks Article III standing, a federal court must dismiss without deciding the underlying constitutional claims.

## Conclusion

The court dismissed the states’ challenge to California’s egg-production and egg-sales requirements because the states did not plausibly allege a quasi-sovereign injury affecting a substantial segment of their populations, instead alleging private industry harms and speculative economic effects insufficient for Article III parens patriae standing.


State of Missouri v. Harris, 58 F. Supp. 3d 1059 (E.D. Cal. 2014)