Animal Legal Defense Fund v. Azar

District Court, N.D. California·Decided April 1, 2025·No. 3:20-cv-03703·Unknown

Opinion

ANIMAL LEGAL DEFENSE FUND, et al., Case No. 20-cv-03703-RS Plaintiffs, v. ORDER GRANTING DEFENDANTS’ ROBERT F. KENNEDY JR., et al., JUDGMENT Defendants, and ELANCO ANIMAL HEALTH, Intervenor-Defendant.

Plaintiffs in this action are three advocacy groups: Animal Legal Defense Fund, Food & Water Watch, and Food Animal Concerns Trust. They challenge the decision of defendant Federal Drug Administration (“FDA”) to approve the animal drug Experior for use in cattle feedlots. Elanco Health, the manufacturer of Experior, has intervened as an additional defendant. Experior is touted to reduce the amount of ammonia gas released from the waste of cattle raised for beef. Plaintiffs contend Experior has not been shown to be safe and effective, and that FDA did not adequately consider the drug’s environmental impacts. Plaintiffs assert claims under the Administrative Procedures Act (“APA”), 5 U.S.C. § 551, et seq. for alleged underlying seq., and the National Environmental Policy Act (“NEPA”), 42 U.S.C. § 4321 et seq.1 The parties bring cross-motions for summary judgment. FDA and Elanco are separately represented and filed separate briefs, but their arguments are substantially similar. For the reasons set out below, the motions of FDA and Elanco will be granted, and plaintiffs’ motion will be denied. The product in dispute is “Experior,” which is a trade name. Its active ingredient is a drug called lubabegron, which was originally researched as a possible treatment for human obesity. It was subsequently investigated as an animal drug to improve feed efficiency in cows –i.e., to promote weight gain with less food. Then it was proposed to reduce ammonia and greenhouse gases from cows. Elanco eventually abandoned any additional claims and now asserts an environmental benefit only from reductions in the amounts of ammonia released from cow manure.2 Experior is theorized to function by increasing the percentage of dietary nitrogen that cows utilize, rather than excrete. Nitrogen functions as a form of “crude protein,” an important nutrient in cattle feed. Only 10-30% of dietary nitrogen, however, is “utilized” by a cow, i.e., deposited in their tissue as protein; the remainder is excreted through urine and feces, where it converts to ammonia gas—which is a combination of nitrogen and hydrogen. Thus, the theory is that if the cows utilize more, and excrete less, of the nitrogen in their diet, less ammonia will be released from their manure.

1 The complaint includes a claim for relief based on the FDA’s denial of a stay petition plaintiffs filed under 21 C.F.R. § 10.35. At the hearing on the present motions, the parties agreed that claim need not be reached.

2 The subtext to plaintiffs’ claims is their belief that the negative environmental consequences of large-scale industrial beef production should be addressed by means other than attempting to add drugs to cattle feed. However intuitively persuasive that argument might be, the court’s role in assessing claims under the APA does not include making such policy determinations. Experior is a “β-adrenergic drug.” Such drugs act on β-adrenoceptors, which are cell surface receptors widely distributed throughout the body that mediate the activity of cells. There are different types of adrenoceptors. Within the β type, there are at least 3 subtypes: β1, β2, and β3. β-agonist drugs “agonize” (i.e., stimulate or activate) β-adrenoceptors. Conversely, β- antagonist drugs “antagonize” (i.e., inhibit or block) them. Plaintiffs contend it is well known that β-adrenergic agonist drugs are linked to significantly higher mortality rates in cows due to a host of fatal respiratory, cardiac, and digestive issues, in addition to significant behavioral issues that make animals more likely to be abused and suffer in ways that directly impact food safety and worker health. Thus, plaintiffs contend, Elanco found it “of critical importance” that Experior not be pharmacologically classified as a β-agonist, “to differentiate their product” from other approved β-agonists. After initially warning that additional studies were needed to determine if Experior is an β-agonist or β-antagonist, FDA ultimately recommended it be classified as a “β-agonist/antagonist,” meaning it stimulates some β- receptors and suppresses others. Because this is an APA case, it is not an inquiry under Rule 56 of the Federal Rules of Civil Procedure as to whether there are disputed factual issues for trial. Rather, this is a review on the merits under the APA of the validity of FDA’s approval of Experior. See, Klamath Siskiyou Wildlands Ctr., 962 F.Supp.2d 1230, 1233; see also Sierra Club v. Mainella, 459 F. Supp.2d 76, 89 (D.D.C. 2006) (“[T]he standard set forth in Rule 56(c) does not apply [in an APA case] because of the limited role of a court in reviewing the administrative record.”); McCrary v. Gutierrez, 495 F.Supp.2d 1038, 1041 (N.D. Cal. 2007) (judicial review of agency action under the APA limited to the administrative record).3

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