United States Ninth Circuit

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State of Missouri ex rel. Koster v. Harris, 14-17111

In a suit filed 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, the district court's dismissal for lack of parens patriae standing is affirmed where: 1) plaintiffs 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.

Appellate Information

  • Decided
  • Published 2017/01/17




  • United States Ninth Circuit