JURIST - Paper Chase: Supreme Court rules federal law preempts state slaughterhouse regulation

[JURIST] The US Supreme Court [official website] ruled unanimously [opinion, PDF] Monday in National Meat Association v. Harris [SCOTUSblog backgrounder] that the Federal Meat Inspection Act (FMIA) [text], which requires observation of animals that are unable to walk for possible disease, preempts a subsequent California law [Cal Pen Code § 599f text] requiring slaughterhouses to "immediately euthanize" on its premises any such animals. The court ruled that the FMIA preemption clause prohibits states from creating and enforcing laws that fall within the scope of the federal requirements, even if the state law does not conflict with the federal law:

The FMIA regulates slaughterhouses' handling and treatment of nonambulatory pigs from the moment of their delivery through the end of the meat production process. California's §599f endeavors to regulate the same thing, at the same time, in the same place—except by imposing different requirements. The FMIA expressly preempts such a state law.

The court reversed the US Court of Appeals for the Ninth Circuit ruling [opinion, PDF] that the California law was not preempted.

The court heard oral arguments [JURIST report] in the case in November and seemed skeptical that there was no overlap in the purposes of the two laws. The court granted certiorari [JURIST report] in the case in June. The provisions of the California law were considered and expressly rejected by federal regulators because they eliminate certain federally required ante-mortem inspection of possibly diseased animals. The California legislature enacted the law to control the treatment of nonambulatory animals after a 2008 undercover video [warning: graphic content] released by the Humane Society of the United States [advocacy website] showed slaughterhouse employees dragging, kicking and applying electric shocks to sick animals to move them.