Mark Baker v. United States Food and Drug Administration, et al.

CourtDistrict Court, E.D. California
DecidedSeptember 16, 2025
Docket2:24-cv-02558
StatusUnknown

This text of Mark Baker v. United States Food and Drug Administration, et al. (Mark Baker v. United States Food and Drug Administration, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mark Baker v. United States Food and Drug Administration, et al., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 MARK BAKER, No. 2:24-cv-02558-DC-SCR 12 Plaintiff, 13 v. FINDINGS & RECOMMENDATIONS 14 UNITED STATES FOOD and DRUG ADMINISTRATION, et al., 15 Defendants. 16 17 Plaintiff Mark Baker is an advocate for regulation of LED vehicle headlights and sues the 18 government agencies allegedly responsible for such regulation. Plaintiff is proceeding pro se in 19 this matter, which is referred to the undersigned pursuant to Local Rule 302(c)(21) and 28 U.S.C. 20 § 636(b)(1). Before the Court is Defendants’ motion to dismiss Plaintiff’s complaint—which 21 contains two causes of action—pursuant to Federal Rule of Civil Procedure 12(b)(1) & (6) (ECF 22 No. 9). Opposition and reply briefs were filed. ECF Nos. 10 & 14. The motion was submitted to 23 the Court without oral argument. 24 The Court now recommends that the motion be GRANTED. The Court finds that Plaintiff 25 has standing to pursue his first cause of action, which concerns a statutory requirement that the 26 Secretary of Health and Human Services (“Secretary”) confer with other agencies about 27 regulation of radiation-emitting devices, but fails to state a claim on which relief can be granted 28 for that cause of action. The Court also finds that Plaintiff lacks standing to pursue his second 1 cause of action, which concerns a statutory requirement that the Secretary establish a standards 2 committee on radiation-emitting devices. Given that Plaintiff has already filed and voluntarily 3 dismissed a related lawsuit—making the complaint at issue here the substantive equivalent of an 4 amended complaint—and given that Plaintiff has not proposed additional facts that might cure the 5 deficiencies identified in Defendants’ motion to dismiss, the undersigned recommends that leave 6 to amend not be granted. 7 I. Background and Procedural History 8 Plaintiff has for years advocated for the Food and Drug Administration (“FDA”) and the 9 National Highway Transportation Safety Administration (“NHTSA”), both defendants in this 10 action, to regulate LED headlights, also referred to as “headlamps.” The Soft Lights Foundation, 11 of which Plaintiff is the founder and president, submitted multiple citizen petitions to the FDA 12 seeking such regulations. ECF No. 1 at ¶ 26. In a “Final Response Letter” issued in response to 13 four of those petitions, the FDA denied, inter alia, the Foundation’s request that the FDA 14 “regulate electromagnetic radiation in the visible portion of the spectrum emitted by products that 15 use [LEDs] and that these regulations set restrictions on spatial non-uniformity, chip-level peak 16 luminance and peak radiance, spectral power distribution, and square wave flicker to protect the 17 physical and psychological health, safety, comfort, and civil rights of those who are negatively 18 impacted by LED light.” ECF No. 9-2 at 2.1 The FDA denied similar requests as to pulsing, 19 flashing, and strobing LEDs, as to LEDs “that are used on vehicles,” and as to LED street lights. 20 Id. at 3. The FDA provided several reasons for denying the requests, including that (1) 21 “regulations for specific performance standards for every type of electronic product” are not 22 “necessary given the effectiveness of existing mitigations in addressing unnecessary radiation and 23 alternative approaches to protect public health” and “the fact that most products do not produce 24 types of levels of unnecessary radiation that pose a risk to public health”; (2) specific standards 25

26 1 Plaintiff discusses those petitions and the agency’s response letter in the complaint in this case. ECF No 1 at ¶¶ 25-27. The Court deems them incorporated by reference. See Khoja v. Orexigen 27 Therapeutics, Inc., 899 F.3d 988, 1002-1003 (9th Cir. 2018). Even if not incorporated by reference, they would be subject to judicial notice, for the reasons described by Defendants. ECF 28 No. 9-1 at 2 n.1. 1 for LEDs are not necessary “due to their long history of safety with respect to the visible 2 wavelengths being emitted,” and (3) the Soft Lights Foundation had provided insufficient 3 evidence that the requested standards are necessary. Id. at 6-7. 4 Plaintiff also sent a letter and email to the NHTSA regarding that agency’s regulation of 5 LED headlamps. ECF No. 1 at ¶ 28. NHTSA responded in a letter—logged as Interpretation 6 571.108-NCC-230201-001, LED Headlights—explaining that “LEDs are allowed to be used as a 7 light source in integral beam headlamps as long as the headlamp conforms to all applicable 8 headlamp requirements in” the agency’s headlamp regulation, known as Standard No. 108, 49 9 C.F.R. § 571.108. Interpretation 571.108-NCC-230201-001, LED Headlights (Feb. 13, 2024).2 10 NHTSA acknowledged the problem of consumers’ illegal replacement of headlamp bulbs with 11 after-market LED bulbs, but noted that NHTSA “generally does not regulate modifications 12 individuals make to their own vehicles,” which instead is a matter “left to State law to address[.]” 13 Id. 14 On September 23, 2024, Plaintiff filed this action, suing the FDA, the NHTSA, officials 15 within each agency, and the Secretary.3 Plaintiff alleges that Defendants have failed in their 16 statutory duty to “maintain a liaison on techniques, equipment, and programs for testing and 17 evaluating Visible Light radiation from Light Emitting Diode (LED) vehicle headlamps.” ECF 18 No. 1 at ¶ 1. Additionally, Plaintiff alleges that the FDA unlawfully dissolved the Technical 19 Electronic Product Radiation Safety Standards Committee (hereafter the “Safety Committee”). 20 Id. Plaintiff contends he has suffered injury via eye pain and “neurological and psychological 21 trauma” from being exposed to the LED headlamps and that his injury is redressable because the 22 23 2 A copy of NHTSA’s response letter to Plaintiff is available here: https://perma.cc/M757-7UHF. 24 That letter is subject to incorporation by reference or judicial notice for the same reasons that apply to the FDA petitions and response letter. 25 3 Plaintiff filed an earlier action, Baker v. FDA, et al., 2:24-cv-00278-DC-SCR, that raised 26 similar claims concerning the alleged lack of regulation of radiation in LED light bulbs. Shortly after the hearing on a motion to dismiss that action, Plaintiff moved to voluntarily dismiss it. 27 That same week, he filed the instant Complaint. The two cases were related. See Case No. 2:24- cv-00278-DC-SCR, ECF No. 24. The Court granted voluntary dismissal in the prior action, and 28 the Court never adjudicated Defendant’s motion to dismiss in that action. 1 FDA could be ordered to reconstitute the Safety Committee and to maintain a liaison to address 2 health and safety impacts of LED vehicle headlamps. Id. at ¶¶ 18-19. 3 On December 3, 2024, Defendants moved to dismiss the action, arguing that Plaintiff 4 lacks standing and fails to state a claim. ECF No. 9-1. The motion is fully briefed and was 5 submitted without oral argument. 6 II. Legal Standards 7 A. Motion to Dismiss Under Rule 12(b)(1) 8 A motion under Rule 12(b)(1) challenges the court’s subject-matter jurisdiction over the 9 action. Such a jurisdictional challenge can be either facial or factual. Leite v. Crane Co., 749 10 F.3d 1117, 1121 (9th Cir. 2014). “A facial attack accepts the truth of the plaintiffs allegations but 11 asserts that they ‘are insufficient on their face to invoke federal jurisdiction.’” Id., citing Safe Air 12 for Everyone v. Meyer, 373 F.3d 1035, 1039 (9th Cir. 2004).

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Bluebook (online)
Mark Baker v. United States Food and Drug Administration, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mark-baker-v-united-states-food-and-drug-administration-et-al-caed-2025.