National Meat Association v. Harris

In 1906 Congress passed the Federal Meat Inspection Act (the inspection act), which authorized the Food Safety and Inspection Service (the service) to inspect animals prior to slaughter to ensure their meat was safe for human consumption. Congress included an express preemptive clause prohibiting states from imposing additional or different regulations concerning slaughterhouse facilities and operations. Pursuant to the inspection act and the Humane Methods of Slaughter Act, regulations concerning the service’s inspection methods were promulgated. Under the regulations, if the service inspected a nonambulatory animal but could not determine whether the animal had a disease rendering its meat unsafe for human consumption, then the animal had to be slaughtered separately from other animals. The service then had to reinspect the animal’s carcass to decide whether the meat was safe to consume. The regulations also provided that some animals delivered to slaughterhouses may not be slaughtered for meat, such as nonambulatory cattle. In 2010 the California legislature enacted § 599f of the penal code, which prohibited meat-producing actors from buying, slaughtering, or selling as meat all nonambulatory animals. The National Meat Association (plaintiff) sued Attorney General Kamala Harris (defendant) on the ground that the inspection act preempted § 599f. Harris, with support from the Humane Society of the United States, argued that § 599f was outside the inspection act’s preemption scope by regulating the purchase of nonambulatory animals prior to the animals’ delivery at the slaughterhouse and by regulating the selling of meat after slaughter. The district court found § 599f was preempted and issued a preliminary injunction preventing enforcement. The circuit court reversed, holding that § 599f only regulated which animals could be slaughtered rather than the inspecting and slaughtering process. The matter was appealed to the United States Supreme Court.