Physicians Committee for Responsible Medicine v. Vilsack

CourtDistrict Court, N.D. California
DecidedFebruary 9, 2023
Docket3:21-cv-03088
StatusUnknown

This text of Physicians Committee for Responsible Medicine v. Vilsack (Physicians Committee for Responsible Medicine v. Vilsack) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Physicians Committee for Responsible Medicine v. Vilsack, (N.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 PHYSICIANS COMMITTEE FOR 10 RESPONSIBLE MEDICINE, et al., Case No. 21-cv-03088-RS

11 Plaintiffs, ORDER GRANTING MOTION TO 12 v. DISMISS

13 TOM VILSACK, et al., 14 Defendants.

15 I. INTRODUCTION 16 In this action, Plaintiffs Physicians Committee for Responsible Medicine and three 17 individual physicians challenge the Dietary Guidelines for Americans under the Administrative 18 Procedure Act, claiming the Guidelines contain misinformation and harm both the organization 19 and its members. Defendants United States Department of Agriculture and Department of Health 20 and Human Services move to dismiss. For the reasons set forth below, the motion to dismiss is 21 granted for both lack of standing and failure to state a claim. 22 II. BACKGROUND1 23 Beginning in 1980 and every five years thereafter, the United States Department of 24 Agriculture and the Department of Health and Human Services have jointly published a report 25 entitled the Dietary Guidelines for Americans (“Guidelines”), which provides advice and 26 27 1 The factual background is based on the well-pled allegations in the complaint, which are taken as 1 recommendations on nutrition and healthy eating. As mandated by law, the Guidelines “shall 2 contain nutritional and dietary information and guidelines for the general public” that is “based on 3 the preponderance of the scientific and medical knowledge which is current at the time the report 4 is prepared,” and “shall be promoted by each Federal agency in carrying out any Federal food, 5 nutrition, or health program.” 7 U.S.C. § 5341(a)(1)-(2). These Guidelines are then used as the 6 basis of the government’s “food assistance and meal programs, nutrition education efforts, and 7 decisions about national2 health objectives.” Guidelines at 12. In some instances, adherence to the 8 Guidelines is a condition of receiving grant funds for specific programs. The latest version of these 9 Guidelines, the 2020-2025 edition, was published in December 2020. 10 Established in 1985, the Physicians Committee for Responsible Medicine (“PCRM”) is a 11 “nonprofit public health organization that advocates for preventive medicine through proper 12 nutrition, encourages higher standards for ethics and effectiveness in medical research, and 13 conducts clinical research on the relationships between food and disease,” Dkt. 24 at 3. PCRM 14 claims to represent more than 175,000 members, including 17,000 physicians, and, along with 15 three individual physicians (Seth Ammerman, Donald Forrester, and Heather Shenkman) 16 (together, “Plaintiffs”), brings suit under the Administrative Procedure Act (“APA”), 5 U.S.C. 17 § 706, challenging the Guidelines. In particular, Plaintiffs object to the Guidelines’ inclusion of 18 dairy products and meat, and the failure adequately to highlight the risks of both, which Plaintiffs 19 claim does not reflect the preponderance of current scientific and medical knowledge, and thereby 20 constitutes arbitrary and capricious agency action. 21 Plaintiffs request a declaratory judgment that the Guidelines violate the APA by failing to 22 reflect the preponderance of current scientific and medical knowledge; and an order to Defendants 23 to: (1) withdraw portions of the Guidelines that hide the ill effects of consuming meat and dairy; 24 (2) withdraw portions of the Guidelines that do not include beans, peas, and lentils as acceptable 25 protein sources; and (3) remove the statement that healthy diets must feature dairy products. 26

27 2 The Guidelines have also been incorporated into various state regulations. 1 III. LEGAL STANDARDS 2 Article III of the U.S. Constitution authorizes the judiciary to adjudicate only “cases” and 3 “controversies.” The doctrine of standing is “an essential and unchanging part of the case-or- 4 controversy requirement of Article III.” Lujan v. Defs. of Wildlife, 504 U.S. 555, 560 (1992). 5 Defendants move to dismiss on the basis that Plaintiffs lack standing under Rule 12(b)(1) of the 6 Federal Rules of Civil Procedure. A 12(b)(1) motion to dismiss a complaint challenges the court’s 7 subject matter jurisdiction over the asserted claims. It is the plaintiff’s burden to prove jurisdiction 8 at the time the action is commenced. Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016). 9 “A Rule 12(b)(1) jurisdictional attack may be facial or factual.” Safe Air for Everyone v. 10 Meyer, 373 F.3d 1035, 1039 (9th Cir. 2004). “In a facial attack, the challenger asserts that the 11 allegations contained in the complaint are insufficient on their face to invoke federal jurisdiction.” 12 Id. Accordingly, when considering this type of challenge, the court is required to “accept as true 13 the allegations of the complaint.” U.S. ex rel. Lujan v. Hughes Aircraft Co., 243 F.3d 1181, 1189 14 (9th Cir. 2001). However, “the district court is not restricted to the pleadings, but may review any 15 evidence, such as affidavits and testimony, to resolve factual disputes concerning the existence of 16 jurisdiction.” McCarthy v. United States, 850 F.2d 558, 560 (9th Cir. 1988). 17 Defendants also allege that Plaintiffs fail to state a claim. A complaint must contain “a 18 short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 19 8(a)(2). While “detailed factual allegations” are not required, a complaint must have sufficient 20 factual allegations to state a claim that is “plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 21 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555, 570 (2007)). A claim is facially 22 plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable 23 inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 24 556). This standard asks for “more than a sheer possibility that a defendant has acted unlawfully.” 25 Id. The determination is a context-specific task requiring the court “to draw on its judicial 26 experience and common sense.” Id. at 679. 27 A Rule 12(b)(6) motion to dismiss tests the sufficiency of the claims alleged in the 1 complaint. Dismissal under Rule 12(b)(6) may be based on either the “lack of a cognizable legal 2 theory” or on “the absence of sufficient facts alleged under a cognizable legal theory.” See 3 Conservation Force v. Salazar, 646 F.3d 1240, 1242 (9th Cir. 2011) (internal quotation marks and 4 citation omitted). When evaluating such a motion, the court must accept all material allegations in 5 the complaint as true and construe them in the light most favorable to the non-moving party. In re 6 Quality Sys., Inc. Sec. Litig., 865 F.3d 1130, 1140 (9th Cir. 2017). It must also “draw all 7 reasonable inferences in favor of the nonmoving party.” Usher v. City of Los Angeles, 828 F.2d 8 556, 561 (9th Cir. 1987). 9 IV. DISCUSSION 10 A.

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Physicians Committee for Responsible Medicine v. Vilsack, Counsel Stack Legal Research, https://law.counselstack.com/opinion/physicians-committee-for-responsible-medicine-v-vilsack-cand-2023.