Upside Foods Inc v. Commissioner, Florida Department of Agriculture an

CourtCourt of Appeals for the Eleventh Circuit
DecidedMarch 23, 2026
Docket24-13640
StatusPublished

This text of Upside Foods Inc v. Commissioner, Florida Department of Agriculture an (Upside Foods Inc v. Commissioner, Florida Department of Agriculture an) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Upside Foods Inc v. Commissioner, Florida Department of Agriculture an, (11th Cir. 2026).

Opinion

USCA11 Case: 24-13640 Document: 79-1 Date Filed: 03/23/2026 Page: 1 of 33

FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-13640 ____________________

UPSIDE FOODS INC, Plaintiff-Appellant, versus

COMMISSIONER, FLORIDA DEPARTMENT OF AGRICULTURE AND CONSUMER SERVICES, ATTORNEY GENERAL, STATE OF FLORIDA, STATE ATTORNEY, THE SECOND JUDICIAL CIRCUIT OF FLORIDA, STATE ATTORNEY, THE SIXTH JUDICIAL CIRCUIT OF FLORIDA, STATE ATTORNEY, 9TH JUDICIAL CIRCUIT, et al., Defendants-Appellees. USCA11 Case: 24-13640 Document: 79-1 Date Filed: 03/23/2026 Page: 2 of 33

2 Opinion of the Court 24-13640 ____________________ Appeal from the United States District Court for the Northern District of Florida D.C. Docket No. 4:24-cv-00316-MW-MAF ____________________

Before NEWSOM and BRASHER, Circuit Judges, and HUCK, ∗ District Judge. BRASHER, Circuit Judge: The question in this appeal is whether the Poultry Products Inspection Act preempts a Florida law that bans the sale of lab- grown chicken. Florida’s SB 1084 outlaws the manufacture, distri- bution, and sale of all lab-grown meat in the state. Fla. Stat. § 500.452(1)–(6). Upside Foods, Inc. is a startup based in California that makes lab-grown meat, including chicken, and would like to distribute and sell its chicken product in Florida. Upside has chal- lenged SB 1084 as preempted under the federal Poultry Products Inspection Act and has moved to preliminarily enjoin its enforce- ment. The district court denied Upside’s motion, ruling that Upside was unlikely to succeed on its preemption claims because a ban on lab-grown chicken is not equivalent to a regulation of Upside’s in- gredients, premises, facilities, or operations. We must wade through a morass of justiciability and other preliminary issues be- fore we can reach the merits. But the bottom line is that we agree with the district court. Because Florida’s ban on lab-grown meat

∗ Honorable Paul C. Huck, United States District Judge for the Southern Dis-

trict of Florida, sitting by designation. USCA11 Case: 24-13640 Document: 79-1 Date Filed: 03/23/2026 Page: 3 of 33

24-13640 Opinion of the Court 3

does not regulate Upside’s ingredients, premises, facilities, or oper- ations, federal law does not preempt SB 1084. Accordingly, we af- firm. I.

We begin by summarizing the relevant provisions of the Poultry Products Inspection Act before examining the origins of this lawsuit and tracing its procedural history. A.

Congress enacted the Poultry Products Inspection Act in 1957 to require the Secretary of Agriculture to establish uniform federal standards for poultry products, 21 U.S.C. §§ 451, 455–57, and to inspect poultry products to prevent them from being “adul- terated or misbranded.” Id. § 452. To help the Secretary implement these uniform standards, the PPIA contains two express preemp- tion provisions: the Ingredients Provision and the Facilities Provi- sion. The Ingredients Provision preempts state laws that require additional or different “ingredient requirements . . . with respect to articles prepared at any official establishment . . . .” Id. § 467e. The Facilities Provision preempts state laws with additional or different requirements “with respect to premises, facilities and operations of any official establishment . . . .” Id. The language of the PPIA re- sembles that of a companion statute, the Federal Meat Inspection Act, which governs meat products much like the PPIA governs poultry products, see id. § 603(a), and contains near-identical Facili- ties and Ingredients Provisions. See id. § 678. USCA11 Case: 24-13640 Document: 79-1 Date Filed: 03/23/2026 Page: 4 of 33

4 Opinion of the Court 24-13640

To be governed by the PPIA, a facility must be an “official establishment.” Id. § 453(p). Because Upside has received a U.S. De- partment of Agriculture Grant of Inspection, it is considered an “of- ficial establishment” and is thus subject to the PPIA. See Upside Foods, Inc., U.S. Dep’t of Agric. (last visited Jan. 22, 2026) [https://perma.cc/X4V3-LPF5]. The PPIA defines “poultry” as “any domesticated bird, whether live or dead,” and defines “poultry product” as “any poul- try carcass, or part thereof; or any product which is made wholly or in part from any poultry carcass or part thereof.” Id. §§ 453(e)– (f). The USDA has repeatedly characterized lab-grown chicken as “poultry food products” and determined that existing regulatory requirements apply to lab-grown poultry. See FSIS Responsibilities in Establishments Producing Cell-Cultured Meat and Poultry Food Products, U.S. Dep’t of Agric., at 1–2 (June 21, 2023), [https://perma.cc/7VUP-2KRN]; see also Human Food Made with Cultured Animal Cells, U.S. Dep’t of Agric. (last visited Oct. 7, 2025), [https://perma.cc/7JVC-27E8]. Finally, the PPIA requires that “[a]ll proceedings for the en- forcement or to restrain violations of [the PPIA] shall be by and in the name of the United States.” 21 U.S.C. § 467c. B.

We draw the following facts from Upside’s evidentiary sub- mission in support of its motion for a preliminary injunction. Up- side produces lab-grown chicken by banking embryonic chicken cells, placing them in a “cultivator,” supplying them with the same USCA11 Case: 24-13640 Document: 79-1 Date Filed: 03/23/2026 Page: 5 of 33

24-13640 Opinion of the Court 5

nutrients they would receive in an animal’s body, and forming the resulting product into a shape that looks like conventional meat— for example, a chicken breast. Upside’s founder and CEO, Uma Valeti, testified that lab-grown meat can replicate the sensory, taste, and nutritional profile of conventional meat. According to Valeti, Upside’s chicken product “looks, cooks, and tastes, like a conventional boneless, skinless chicken cutlet.” Doc. 11-3 ¶ 24. Val- eti explained that Upside’s goal is to produce a meat product that avoids ethical, environmental, and health concerns related to slaughtered or conventional meat. Upside has completed a pre-market consultation with the Food and Drug Administration, and the FDA issued Upside a letter stating that the FDA had “no questions” as well as a scientific mem- orandum regarding the safety of Upside’s lab-grown chicken. The USDA’s Food Safety and Inspection Service has also issued product labeling approval and a Grant of Inspection to Upside, allowing it to sell its lab-grown chicken in interstate commerce. Upside under- goes the same kind of routine federal inspection of its facility as do producers of conventional meat. After Upside received these federal approvals, the company began distributing its product in California and has showcased its product in at least four other states (including Florida). In Florida, before SB 1084 went into effect, Upside held a tasting event in Mi- ami and talked with a Florida chef who was interested in serving lab-grown chicken. Upside also alleges that it was planning to hold at least two other tasting events in Miami—one at the Art Basel USCA11 Case: 24-13640 Document: 79-1 Date Filed: 03/23/2026 Page: 6 of 33

6 Opinion of the Court 24-13640

event in December 2024, and another at the South Beach Wine and Food Festival in February 2025. Upside wishes to continue devel- oping business relationships with Florida chefs because Florida contains the headquarters of the world’s largest full-service restau- rant company and one of the largest quick service restaurants in the world, and it is the third-most populous state in the country.

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