NATIONAL MEAT ASSOCIATION v. HARRIS

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Case Basics
Docket No. 
10-224
Petitioner 
National Meat Association
Respondent 
Kamala D. Harris, Attorney General of California, et al.
Decided By 
Advocates
(for the petitioner)
(Assistant to the Solicitor Gen­eral, Department of Justice, for United States, as amicus curiae, supporting the petitioner)
(Deputy Attorney General of California, for the respondents)
Term:
Facts of the Case 

The National Meat Association contends that the Federal Meat Inspection Act prevents California from imposing its requirements on federally inspected slaughterhouses. In 2008, the state enacted the law after the Humane Society of the United States released a video of so-called downer cows being kicked, electrocuted, dragged with chains and rammed with a forklift at a slaughterhouse.
The California law bans slaughterhouses from buying or selling downer cows and from butchering them for human consumption. The measure also requires humane handling of the animals.

The U.S. Court of Appeals for the Ninth Circuit refused to grant a preliminary injunction blocking the law. Although the court said the humane-handling provision probably was pre-empted by federal law, the three-judge panel declined to block it, saying the trade group hadn't shown its members would suffer "irreparable injury."

Question 

Is a California law requiring slaughterhouses to "immediately euthanize" any nonambulatory animal on its premises preempted by the Federal Meat Inspection Act?

Conclusion 
Decision: 9 votes for National Meat Association, 0 vote(s) against
Legal provision: Federal Meat Inspection Act, 21 U. S. C. §60

Yes. In a unanimous decision authored by Justice Elena Kagan, Court reversed the lower court, holding that the Federal Meat Inspection Act's preemption clause applied broadly to any additional or different regulations a state imposes on slaughterhouses. The act prevails even where state law does not conflict with the federal act. The Court rejected arguments that the Act did not apply to animals rendered non-ambulatory before reaching the slaughterhouse. The Court also held that the criminal penalties imposed by the state law were more than a mere incentive to improve humane animal slaughter practices.

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NATIONAL MEAT ASSOCIATION v. HARRIS . The Oyez Project at IIT Chicago-Kent College of Law. 31 August 2014. <http://www.oyez.org/cases/2010-2019/2011/2011_10_224>.
NATIONAL MEAT ASSOCIATION v. HARRIS , The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2011/2011_10_224 (last visited August 31, 2014).
"NATIONAL MEAT ASSOCIATION v. HARRIS ," The Oyez Project at IIT Chicago-Kent College of Law, accessed August 31, 2014, http://www.oyez.org/cases/2010-2019/2011/2011_10_224.