Jones v. Rath Packing Co.
430 U.S. 519 (1977)
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Rule of Law:
A state law is preempted by federal law if it imposes labeling requirements that are expressly "different than" those under a federal act, or if it implicitly stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress, such as facilitating consumer value comparisons.
Facts:
- Rath Packing Co. (Rath) packages and sells bacon, and General Mills, Inc., Pillsbury Co., and Seaboard Allied Milling Corp. (the millers) package and sell flour.
- The packaged bacon is subject to federal regulation under the Federal Meat Inspection Act (FMIA), and the packaged flour is subject to the Federal Food, Drug, and Cosmetic Act (FDCA) and the Fair Packaging and Labeling Act (FPLA).
- Both bacon and flour are commodities that naturally lose moisture and, therefore, weight after packaging and during distribution.
- Federal regulations for both meat and flour permit reasonable variations from the stated net weight on a package if caused by moisture loss during good distribution practices.
- M. H. Jones, the Director of the Department of Weights and Measures in Riverside County, California, ordered Rath's bacon and the millers' flour to be removed from sale.
- Jones's order was based on a California law requiring the average weight of packages in a sampled lot to be no less than the stated weight, which does not recognize moisture loss as a justification for any shortfall.
Procedural Posture:
- Rath Packing Co. and several milling corporations filed separate suits against Jones in the U.S. District Court for the Central District of California.
- The plaintiffs sought declaratory judgments that the California law was preempted by federal law and injunctions prohibiting its enforcement.
- The District Court, a court of first instance, granted the requested relief, finding the state law was preempted.
- Jones, as the defendant, appealed the decision to the U.S. Court of Appeals for the Ninth Circuit.
- The Court of Appeals, an intermediate appellate court, affirmed the District Court's judgments.
- Jones, as the petitioner, sought and was granted a writ of certiorari from the U.S. Supreme Court.
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Issue:
Does federal law, specifically the Federal Meat Inspection Act and the Fair Packaging and Labeling Act, preempt a California statute that requires the average net weight of packaged goods to equal or exceed the stated net weight, with no allowance for weight loss due to moisture loss during distribution?
Opinions:
Majority - Mr. Justice Marshall
Yes, federal law preempts the California statute. With respect to bacon, the Federal Meat Inspection Act (FMIA) contains an express preemption clause that prohibits states from imposing labeling requirements "in addition to, or different than" those made under the Act. Since federal regulations permit reasonable variations from stated weight due to moisture loss during distribution and California's law does not, the state's requirement is "different than" the federal standard and is therefore expressly preempted. With respect to flour, the Fair Packaging and Labeling Act (FPLA) does not expressly preempt the state law. However, the state law is implicitly preempted because it conflicts with a primary purpose of the FPLA: facilitating value comparisons for consumers. To comply with California's stricter standard, national millers would have to overpack flour to account for potential moisture loss, meaning identically labeled packages sold across the country would contain different amounts of flour solids. This frustrates the congressional objective of uniform labeling for value comparison, making the state law an unconstitutional obstacle to the execution of federal purposes.
Concurring in part and dissenting in part - Mr. Justice Rehnquist
Yes, in part, and no, in part. The California law is preempted as to bacon, but not as to flour. I agree with the majority that the express preemption clause of the Federal Meat Inspection Act (FMIA) clearly bars California's 'different' labeling requirement for bacon. However, the Court's finding of implied preemption for flour is based on 'unwarranted speculations' about market effects rather than the required 'clear demonstration of conflict.' It is physically possible for millers to comply with both the federal and state laws. The majority's conclusion that the state law frustrates the federal purpose of 'value comparison' is not inevitable and fails to meet the high standard required to preempt state laws in a field of traditional state police power.
Analysis:
This case provides a clear illustration of two distinct types of federal preemption: express and implied (conflict) preemption. It establishes that a state regulation is expressly preempted when a federal statute's language explicitly forbids different state-level rules. More significantly, it demonstrates that even absent explicit language, a state law is implicitly preempted if its practical effect creates an 'obstacle' to achieving a key federal objective. By invalidating the California law for flour on the grounds that it undermined the federal goal of facilitating consumer 'value comparisons,' the Court broadened the application of conflict preemption, prioritizing national uniformity in commerce over state-level consumer protection standards that differ from the federal scheme.
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