State of Missouri ex rel. Koster v. Harris, No. 14-17111 (9th Cir. 2016)
Annotate this CasePlaintiffs, six states, filed suit seeking to block enforcement of California's laws and regulations prescribing standards for the conditions under which chickens must be kept in order for their eggs to be sold in the state. Plaintiffs seek to block enforcement before the laws and regulations take effect. The court agreed with the district court that plaintiffs lacked standing to bring this case as parens patriae where plaintiffs failed to demonstrate an interest apart from the interests of particular private parties because plaintiffs' alleged harm to the egg farmers in plaintiffs' states is insufficient to satisfy the first prong of parens patriae; plaintiffs' allegations regarding the potential economic effects of the laws, after implementation, were necessarily speculative; and plaintiffs’ reliance on cases granting parens patriae standing to challenge discrimination against a state’s citizens is misplaced where the laws do not distinguish among eggs based on their state of origin. The court also concluded that plaintiffs would be unable to assert parens patriae standing in an amended complaint. Because plaintiffs could allege post-effective-date facts that might support standing, the complaint should have been dismissed without prejudice. Accordingly, the court affirmed the judgment and remanded with instructions to dismiss the action without prejudice.
Court Description: Civil Rights. The panel affirmed the district court’s dismissal of an action for lack of parens patriae standing but remanded with instructions to dismiss without prejudice. Plaintiffs are six states seeking to block enforcement of California laws and regulations prescribing standards for the conditions under which chickens must be kept in order for their eggs to be sold in the state. Plaintiffs sought to block the laws before they took effect. The panel held that the STATE OF MISSOURI EX REL.KOSTER V. HARRIS 3 plaintiffs failed to establish parens patriae standing because: (1) they failed to articulate an interest apart from the interests of private egg producers, who could have filed an action on their own behalf; (2) the allegations about potential economic effects of the challenged laws, after implementation, were necessarily speculative; and (3) the allegations of discrimination were misplaced because the laws do not distinguish among eggs based on their state of origin. The panel further held that the district court did not err by denying leave to amend because plaintiffs would be unable to assert parens patriae standing in an amended complaint. The panel held that because in theory, plaintiffs could allege post-effective-date facts that might support standing, the complaint should have been dismissed without prejudice.
The court issued a subsequent related opinion or order on January 17, 2017.
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