Justia Agriculture Law Opinion Summaries

Petitioner, a trade association representing meatpackers and processors, sued to enjoin enforcement of a California law against swine slaughterhouses, arguing that the Federal Meat Inspection Act (FMIA), 21 U.S.C. 601, et seq., preempted application of the law. The California law dictated what slaughterhouses must do with pigs that could not walk, known in the trade as nonambulatory pigs. The Court concluded that the FMIA regulated slaughterhouses' handling and treatment of nonambulatory pigs from the moment of their delivery through the end of the meat production process. California's law endeavored to regulate the same thing, at the same time, in the same place - except by imposing different requirements. The FMIA expressly preempted such a state law. Accordingly, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings. View "National Meat Assn. v. Harris" on Justia Law

The Agricultural Marketing Agreement Act of 1937 (AMAA), enacted to stabilize prices for agricultural commodities, regulate “handlers,” defined as “processors, associations of producers, and others engaged in the handling” of covered agricultural commodities, 7 U.S.C. 608c(1). The California Raisin Marketing Order, promulgated under the AMAA, established a Raisin Administrative Committee, which recommends annual reserve pools of raisins not to be sold on the open domestic market and requires handlers to pay assessments to help cover administrative costs. The petitioners, raisin producers, refused to surrender requisite portions of raisins to the reserve. The USDA began administrative proceedings. An ALJ found that petitioners were handlers and had violated the AMAA and the Order, and rejected a takings defense. The district court entered summary judgment for the USDA. The Ninth Circuit affirmed. A unanimous Supreme Court reversed, holding that the Ninth Circuit had jurisdiction to decide the takings claim. Petitioners argued that they were producers, not subject to the AMAA or the Order, but the USDA and the district court concluded that they were handlers. Fines and penalties were levied on them in that capacity. Their takings claim, therefore, was necessarily raised in that capacity. The Ninth Circuit confused a statutory argument that they were producers with a constitutional argument that, if they were handlers, their fine violated the Fifth Amendment. The claim was ripe. The petitioners were subject to a final agency order; because the AMAA provides a comprehensive remedial scheme that withdraws Tucker Act jurisdiction over a handler’s takings claim, there is no alternative remedy. View "Horne v. Department of Agriculture" on Justia Law

Petitioner, a trade association representing meatpackers and processors, sued to enjoin enforcement of a California law against swine slaughterhouses, arguing that the Federal Meat Inspection Act (FMIA), 21 U.S.C. 601, et seq., preempted application of the law. The California law dictated what slaughterhouses must do with pigs that could not walk, known in the trade as nonambulatory pigs. The Court concluded that the FMIA regulated slaughterhouses' handling and treatment of nonambulatory pigs from the moment of their delivery through the end of the meat production process. California's law endeavored to regulate the same thing, at the same time, in the same place - except by imposing different requirements. The FMIA expressly preempted such a state law. Accordingly, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings. View "National Meat Assn. v. Harris" on Justia Law