Animal Legal Defense Fund Boston, Inc. v. Provimi Veal Corp.
United States District Court for the District of Massachusetts
626 F. Supp. 278 (1986)
- Written by Haley Gintis, JD
Facts
In 1985 the Animal Legal Defense Fund Boston, Inc. (ALDF) (plaintiff) sued the Provimi Veal Corporation (Provimi) (defendant). ALDF filed the action under Massachusetts’s consumer-protection statute (Chapter 93A), which prohibited unfair and deceptive trade practices. ALDF alleged that Provimi engaged in animal cruelty by directing that its calves raised for human consumption were ill-fed and raised in cramped pens. ALDF claimed that Provimi engaged in unfair and deceptive marketing practices in violation of Chapter 93A by failing to disclose to veal consumers that the meat came from mistreated calves. ALDF asserted standing to sue under Chapter 93A on the ground that the statute created a private right of action to sue for animal cruelty if the cruelty affected consumers. According to ALDF, Provimi’s animal-cruelty actions affected consumers because disclosing the treatment was likely to influence buyers not to purchase meat from Provimi for humanitarian and health reasons, because the calves were medicated with antibiotic drugs harmful to humans. In response to the complaint, Provimi asserted several defenses. One defense was that animal-cruelty violations could not be privately enforced through Chapter 93A. A second defense was that multiple federal laws preempted ALDF’s claim. Provimi submitted a motion for a judgment on the pleadings.
Rule of Law
Issue
Holding and Reasoning (Mazzone, J.)
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