Narrative Opinion Summary
This case involves a challenge to a City of Phoenix ordinance prohibiting pet stores from selling dogs and cats sourced from commercial breeders. Plaintiffs contested the ordinance on grounds of constitutional violations, including the Dormant Commerce and Equal Protection Clauses, and alleged preemption by state law. The district court ruled in favor of the City and the Humane Society of the United States (HSUS), upholding the ordinance's constitutionality. However, during the appeal, Arizona passed State Bill 1248, explicitly allowing pet stores to source animals from USDA-compliant breeders and preempting stricter local ordinances. The Ninth Circuit remanded the case, and upon review, the district court vacated its prior judgment, finding the new law preempted the ordinance. The court emphasized Arizona's home-rule charter analysis, which allows state law to prevail in matters of statewide concern, concluding that pet store regulation involves such state interests. While the defendants and HSUS opposed vacatur, arguing the plaintiffs influenced the legislative change, the court determined the plaintiffs did not cause the law's enactment and thus granted vacatur. The case underscores the preemptive power of state legislation over local ordinances in matters deemed of statewide significance.
Legal Issues Addressed
Dormant Commerce and Equal Protection Clausessubscribe to see similar legal issues
Application: The plaintiffs argued that the City of Phoenix's ordinance violated these clauses, but the court upheld the constitutionality of the ordinance.
Reasoning: They claimed the ordinance violated the Dormant Commerce and Equal Protection Clauses of the U.S. Constitution.
Home Rule Charter and Statewide Concernsubscribe to see similar legal issues
Application: The ordinance was evaluated against Arizona's home-rule charter, and the court concluded it was a matter of statewide concern, thus subject to state law.
Reasoning: The Arizona Supreme Court has clarified that when a state law affects municipal affairs of statewide concern, it prevails over local ordinances.
Legislative Preemption of Local Ordinancessubscribe to see similar legal issues
Application: The new law allowed pet stores to source animals from compliant breeders, preempting local ordinances with stricter sourcing requirements.
Reasoning: The new statute indicates that regulating pet dealers is a statewide concern, supported by the Governor's signing statement.
Preemption by State Lawsubscribe to see similar legal issues
Application: The court found that the newly enacted State Bill 1248 preempted the local ordinance, requiring vacatur of the prior judgment.
Reasoning: The court determined that the new statute preempted the ordinance and decided to vacate the prior summary judgment.
Vacatur and Mootnesssubscribe to see similar legal issues
Application: The court considered whether the plaintiffs' actions rendered the case moot and decided that vacatur was appropriate despite opposition.
Reasoning: Plaintiffs moved to dismiss the appeal, arguing the new law preempted the ordinance and warranted vacating the court's earlier summary judgment.