Full Case Name:  Triumph Foods, LLC v. Rob Bonta et al

Summary: In Triumph Foods, LLC v. Rob Bonta et al., No. 2:25-cv-09063-CAS-AJR (C.D. Cal. Mar. 2, 2026), the United States District Court for the Central District of California granted defendants' and intervenors' motions to dismiss plaintiff's constitutional challenge to California Health & Safety Code § 25990 et seq., commonly known as Proposition 12. Proposition 12 prohibits the sale within California of whole pork meat from breeding pigs confined in a "cruel manner," which the statute defines as confinement that prevents the animal from lying down, standing up, fully extending its limbs, or turning around freely, or that provides less than 24 square feet of usable floorspace per pig. The court held that plaintiff's express and implied preemption claims under the Federal Meat Inspection Act failed as a matter of law because Proposition 12 regulates farm animal confinement standards to prevent animal cruelty rather than slaughterhouse operations, placing it outside the FMIA's preemptive scope. The court further dismissed plaintiff's dormant Commerce Clause claims, finding that the statute is facially nondiscriminatory and that plaintiff failed to plausibly allege that its "slaughterhouse exception" imposes a significant burden on interstate commerce. Plaintiff's Fourteenth Amendment due process vagueness challenge was rejected on grounds that the statutory definitions provide sufficient clarity for persons of ordinary intelligence to understand prohibited conduct. The court also dismissed plaintiff's Import-Export Clause claim as foreclosed by Supreme Court precedent limiting that clause to foreign commerce. The dismissals were with prejudice as to the preemption and Import-Export Clause claims, and without prejudice as to the Commerce Clause and due process claims, with leave to amend granted.