A1A Burrito Works, Inc., et al v. Sysco Jacksonville, Inc., No. 22-11330 (11th Cir. 2023)
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In the United States Court of Appeals for the Eleventh Circuit, a group of Florida restaurants brought a lawsuit against Sysco Jacksonville, Inc., a food distribution company. The restaurants, which include A1A Burrito Works, Inc., A1A Burrito Works Taco Shop 2, Inc., and Juniper Beach Enterprises, Inc., alleged that Sysco violated the Florida Deceptive and Unfair Trade Practices Act (FDUTPA) and breached their contracts when Sysco regularly delivered underweight boxes of poultry. The district court dismissed the restaurants' claims, ruling that the Poultry Products Inspection Act (PPIA) preempted their state law claims because their claims sought to impose on Sysco labeling requirements that are "in addition to, or different than" the requirements prescribed by federal law.
The Eleventh Circuit affirmed in part, reversed in part, and remanded the case for further proceedings. The court agreed with the district court that the restaurants failed to show that their FDUTPA claim was not preempted by the PPIA. However, the court disagreed with the district court's dismissal of the restaurants' breach of contract claim. The court found that this claim, which argued that the restaurants did not receive the amount of poultry they paid for in accordance with their contracts with Sysco, was not preempted because it merely sought to enforce the parties' private agreements regarding the cost and weight of poultry packages and did not amount to a state imposing a labeling requirement inconsistent with federal regulations.
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