National Meat Association, Petitioner v. Kamala D. Harris, Attorney General of California, et al. (565 U.S. 452)
U.S. Supreme Court · decided January 23, 2012 · Supreme Court Database (Spaeth)
- Citation
- 565 U.S. 452 · 132 S. Ct. 965
- Decided
- January 23, 2012
- Term
- October Term 2011
- Vote
- 9–0
- Majority author
- Justice Kagan
- Issue area
- Federalism
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Kagan delivered the opinion of the Court. The Federal Meat Inspection Act (FMIA or Act), 21 U. S. C. § 601 et seq., regulates the inspection, handling, and slaughter of livestock for human consumption. We consider here whether the FMIA expressly preempts a California law dictating what slaughterhouses must do with pigs that cannot walk, known in the trade as nonambulatory pigs. We hold that the FMIA forecloses the challenged applications of the state statute. I A The FMIA regulates a broad range of activities at slaughterhouses to ensure both the safety of meat and the humane handling of animals. First enacted in 1906, after Upton Sinclair’s muckraking novel The Jungle sparked an uproar over conditions in the meatpacking industry, the Act establishes “an elaborate system of inspecting]” live animals and carcasses in order “to prevent the shipment of impure, unwholesome, and unfit meat and meat-food products.” Pittsburgh Melting Co. v. Totten, 248 U. S. 1, 4-5 (1918). And since amended in 1978, see 92 Stat. 1069, the FMIA requires all slaughterhouses to comply with the standards for humane handling and slaughter of animals set out in the Humane Methods of Slaughter Act of 1958 (HMSA), 72 Stat. 862, 7 U. S. C. § 1901 et seq., which originally applied only to slaughterhouses selling meat to the Federal Government. The Department of Agriculture’s Food Safety and…
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