Animal Legal Defense Fund v. Reynolds, No. 22-1830 (8th Cir. 2024)
Annotate this CaseThe United States Court of Appeals for the Eighth Circuit reversed a lower court's decision that an Iowa law violated the First Amendment. The law prohibited accessing an agricultural production facility under false pretenses or making a false statement or misrepresentation as part of a job application at such a facility, with the intent to cause physical or economic harm or other injury to the facility. Various organizations challenged this law, arguing it was unconstitutional as it was "viewpoint-based", targeting speakers with negative views of agricultural production facilities. The United States District Court for the Southern District of Iowa agreed and granted summary judgment for the plaintiffs, enjoining officials from enforcing the law. On appeal, the Eighth Circuit disagreed, finding that the law was constitutional as it restricted intentionally false speech carried out to cause a legally recognized harm. Therefore, the appellate court reversed the judgment, vacated the injunction, and remanded the case for further proceedings.
Court Description: [Colloton, Author, with Grasz and Kobes, Circuit Judges] Civil case - Constitutional law (First Amendment). For the court's prior opinion in the matter, see Animal Legal Defense Fund v. Reynolds, 8 F.4th 781 (8th Cir. 2021), where the court ruled that a provision of Iowa law prohibiting making a false statement or misrepresentation in an employment application was insufficiently tailored and unconstitutional because it encompassed statements that were not material to an employment decision. Iowa passed a new law - Iowa Code Sec. 717A.3(b)(1)(a)-(b)(2019) - addressing the issue and several organizations challenged the new law. The district court concluded that an intent requirement rendered the new law view-point-based and a violation of the First Amendment because it targeted speakers who have negative views of agricultural production facilities. The state officials appeal. Held: The Iowa statute is not a viewpoint=based restriction on speech, but rather a permissible restriction on intentionally false speech undertaken to accomplish a legally cognizable harm.
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