Goodell v. Humboldt County
Iowa Supreme Court
575 N.W.2d 486 (1998)

- Written by Sean Carroll, JD
Facts
Humboldt County (defendant) passed an ordinance requiring anyone who planned to build a livestock-feeding facility to obtain a county permit. As a prerequisite to granting a permit, the county required an applicant to comply with all state livestock regulations. The ordinance provided that if a facility was found to be operating without a permit, the county could bring an enforcement action. Goodell and other livestock producers (plaintiffs) filed suit, claiming that the ordinance was preempted by the state’s regulatory scheme for livestock facilities. Specifically, pursuant to state law, the Department of Natural Resources (DNR) required that certain livestock facilities receive state permits to operate. Further, another state law required the approval of the Environmental Protection Commission (EPC) before an enforcement action could be brought against a livestock facility. The county argued that the ordinance was a permissible zoning ordinance regulating land use within the county. The district court upheld the ordinance. The livestock producers appealed.
Rule of Law
Issue
Holding and Reasoning (Ternus, J.)
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