PETA v. USDA, No. 16-2029 (4th Cir. 2017)Annotate this Case
The Animal Welfare Act does not directly address license renewal but does expressly authorize the USDA to promulgate and implement its own renewal standards. PETA filed suit challenging the license renewal process for animal exhibitors promulgated by the USDA through which the USDA may renew such license despite a licensee's noncompliance with the Act. The Fourth Circuit affirmed the district court's grant of the USDA's Rule 12(c) motion for judgment on the pleadings. The court agreed with the Eleventh Circuit that the Act's licensing regulations embody a reasonable accommodation of the conflicting policy interests Congress has delegated to the USDA and were entitled to Chevron deference.