The Humane Society of the United States v. Perdue

CourtDistrict Court, N.D. California
DecidedFebruary 22, 2024
Docket3:20-cv-01395
StatusUnknown

This text of The Humane Society of the United States v. Perdue (The Humane Society of the United States v. Perdue) 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
The Humane Society of the United States v. Perdue, (N.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 THE HUMANE SOCIETY OF THE Case No. 20-cv-01395-LB UNITED STATES, et al., 12 Plaintiffs, ORDER GRANTING MOTION TO 13 DISMISS v. 14 Re: ECF No. 25 SONNY PERDUE, et al., 15 Defendants. 16 17 INTRODUCTION 18 The plaintiffs are non-profit organizations challenging rules set by the U.S. Department of 19 Agriculture (USDA) on chicken-slaughter line speeds at certain chicken slaughterhouses. A 2014 20 regulation from the USDA’s Food Safety and Inspection Service (FSIS) allows line speeds of 140 21 chickens per minute. In 2018, FSIS began allowing waivers for slaughterhouses that permit line 22 speeds of 175 chickens per minute. Then in 2022, after the change in leadership, the 2018 waivers 23 were terminated and modified waivers were allowed under new criteria (though the new criteria 24 incorporate the 2018 line-speed increase). The plaintiffs challenge the 2018 line-speed-increase 25 decision on the ground that it violates the Administrative Procedure Act (APA). 26 The defendants (USDA, FSIS, and agency officials) moved to dismiss the complaint on the 27 following grounds: (1) lack of standing; (2) the 2018 criteria are not final agency action; and (3) 1 improper venue (assuming that Marin Humane lacks standing). Alternatively, the defendants ask 2 for transfer to the District of Columbia under 28 U.S.C. § 1404(a). 3 The plaintiffs lack standing: given the changed regulatory landscape, they have not met their 4 burden on traceability or redressability (but may be able to do so in an amended complaint). (The 5 plaintiffs do not have organizational standing, but The Humane Society has demonstrated 6 associational standing, at least absent the redressability issues.) The court reserves the other issues 7 for consideration after the filing of an amended complaint. 8 9 STATEMENT 10 1. The Challenged Waiver Decision 11 From 2012 to 2014, FSIS engaged in rulemaking that resulted in the “New Poultry Inspection 12 System,” an optional federal inspection system for chicken slaughterhouses. Under this system, 13 opt-in slaughterhouses could operate at line speeds up to 140 chickens per minute. During the 14 rulemaking, FSIS considered and rejected allowing all opt-in slaughterhouses to use line speeds of 15 up to 175 chickens per minute, but it did allow up to twenty slaughterhouses to do so.1 16 FSIS made its 2018 line-speed-increase decision through a February 2018 Constituent Update 17 and a September 2018 Federal Register notice (and not a rulemaking). The defendants allegedly 18 did not provide “any acceptable justification,” failed to consider issues such as worker safety, and 19 failed to conduct a National Environmental Policy Act (NEPA) review. The 2018 decision, which 20 applies to slaughterhouses that use the New Poultry Inspection System, “clear[ed] the way for 21 dozens of slaughterhouses to kill chickens at an increased rate of 175 [chickens] per minute . . . if 22 [the slaughterhouses] meet certain minimal requirements.” That is, the decision sets out criteria for 23 waivers from the 2014 line-speed regulation. (The plaintiffs thus allege that the 2018 decision 24 amended the 2014 rule.) “Nearly half” of chicken slaughterhouses using the New Poultry 25 Inspection System are eligible for a waiver.2 26 27 1 Am. Compl. – ECF No. 22 at 3 (¶ 4), 36–38 (¶¶ 165–74). Citations refer to material in the Electronic Case File (ECF); pinpoint citations are to the ECF-generated page numbers at the top of documents. 1 The plaintiffs allege that the 2018 decision “will result in more inhumane treatment of 2 chickens, which FSIS has long recognized seriously threatens food safety,” and “will also cause 3 harm to the environment and result in increased risk of injury for slaughterhouse employees.” 4 These problems exist even at line speeds of 140 chickens per minute, but they will be exacerbated 5 at increased line speeds.3 6 The plaintiffs describe the chicken-slaughter process, from transportation from the factory 7 farm, to upside-down shackling on a conveyor line, to passage through electrified water to render 8 the chickens unconscious, to carotid-artery severing by a blade, to submersion of the deceased 9 chickens into a hot-water tank. The plaintiffs allege that each step entails a margin of error such 10 that the intended result at that step is not achieved for a certain number of chickens (but those 11 chickens still proceed to the next step).4 The adverse effects from higher line speeds are essentially 12 that these error rates increase, resulting in problems such as bruising and broken bones (which 13 threaten food safety), inhumane treatment (for example, conscious chickens entering scalding 14 water at the final step), worker injuries (including exposure to chickens’ waste), and 15 environmental harm (such as from increased water and fossil-fuel consumption).5 16 17 2. FSIS’s 2022 Waiver Decision 18 The parties do not dispute that in 2022, FSIS “terminated all line-speed waivers issued 19 pursuant to the 2018 Constituent Update and Federal Register notice and allowed establishments 20 that had received waivers under the 2018 criteria to apply for modified waivers subject to criteria 21 announced in a July 29, 2022 Constituent Update.”6 22 23 24 25 26 3 Id. at 3 (¶ 3), 27 (¶ 105), 28 (¶ 110). 4 Id. at 28–30 (¶¶ 113–23). 27 5 Id. at 30–36 (¶¶ 124–64). 1 3. The Plaintiffs and Their Alleged Interests in the Challenged Waivers 2 The plaintiffs are five non-profit organizations: The Humane Society of the United States, 3 Animal Outlook, Government Accountability Project, Mercy for Animals, and Marin Humane. 4 Their missions relate to animal protection.7 The plaintiffs, again, challenge only FSIS’s 2018 5 waiver decision.8 6 The Humane Society is headquartered in the District of Columbia and has regional offices 7 throughout the country. It “is the largest animal protection organization in the United States, 8 representing millions of members and constituents nationwide.” It “actively advocates for better laws 9 and regulations to protect animals and the environment; conducts mission-specific campaigns to 10 increase protections for domestic animals and wildlife; and advocates against practices that injure, 11 harass, or otherwise harm animals.” Through its farm-animal-welfare campaign, it “endeavors to 12 raise awareness about farm animal confinement, raising, and slaughter practices,” including their 13 effect on pollution and public health, and “advocates to regulate such farm animal practices through 14 efforts with administrative agencies, Congress, state legislatures, and the courts.” FSIS’s 2018 waiver 15 criteria has required The Humane Society to “divert resources . . . to the issue.”9 16 Some of The Humane Society’s members “spend time near” slaughterhouses operating at 17 higher line speeds and some “live near factory farms that supply such slaughterhouses, including 18 members in Batesville, Arkansas; Imboden, Arkansas; and West Columbia, South Carolina.” 19 “These members are subject to aesthetic, health, environmental, and/or other harm resulting from 20 these slaughterhouses’ operations.” In particular, the members are subject to “the noxious stench 21 emitted from such slaughterhouses,” “pollution from trucks carrying chickens on their way to be 22 killed at such facilities,” and the sight of chickens “kept in cruel conditions on the trucks.” These 23 harms “very likely have been and will continue to be worsened because of the increased speeds at 24 which such slaughterhouses operate under the 2018” decision.10 25 26 7 Am. Compl. – ECF No. 22 at 5–21 (¶¶ 11–75). 8 Id. at 27 (¶ 106). 27 9 Id. at 5–7 (¶¶ 11–14). 1 The Humane Society also alleges procedural and informational injuries on behalf of itself and 2 its members.

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Bluebook (online)
The Humane Society of the United States v. Perdue, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-humane-society-of-the-united-states-v-perdue-cand-2024.