Missouri ex rel. Koster v. Harris

847 F.3d 646 (2017)

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Missouri ex rel. Koster v. Harris

United States Court of Appeals for the Ninth Circuit
847 F.3d 646 (2017)

Facts

In 2008, the California legislature passed a law requiring that all egg-producing facilities within the state comply with certain animal-care standards. In 2010, the California legislature passed a law prohibiting the sale of any eggs coming from noncompliant facilities. In 2013, the California Department of Food and Agriculture promulgated additional regulations concerning animal-care standards. The legislation and regulations were intended to go into effect in January 2015. Before the effective date, the Missouri Attorney General Chris Koster (plaintiff) sued California Attorney General Kamala Harris (defendant). Koster argued that the legislation and regulations violated the Commerce Clause and were preempted by federal laws. The complaint was amended so that officials from Nebraska, Oklahoma, Alabama, Kentucky, and Iowa (plaintiffs) could join. The states claimed they had parens patriae standing because the laws harmed their egg farmers by increasing production costs, would cause price fluctuations in eggs sold within their states, and discriminated against non-California citizens. The Humane Society of the United States and the Association of California Egg Farmers (associations) (defendants) joined the action. Harris and the associations filed motions to dismiss. The district court granted the motions with prejudice on the ground that the state officials lacked standing because the parens patriae requirements were not satisfied and because the claim was nonjusticiable.

Rule of Law

Issue

Holding and Reasoning (Graber, J.)

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