Bates v. Dow Agrosciences
Citation
544 U.S. 431 (2005)
Facts
Texas peanut farmers brought state tort and statutory claims against Dow Agrosciences after a pesticide product damaged their crops. Dow argued that the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) preempted the farmers’ state-law claims because FIFRA preempts state “requirements” for labeling that differ from federal requirements.
Issue
Whether FIFRA’s express preemption clause bars state tort claims alleging that a pesticide’s label was defective or inadequate.
Holding
The Court held that FIFRA preempts only state requirements “for labeling or packaging” that differ from federal requirements; state tort claims that parallel federal requirements are not preempted.
Rule
Express preemption clauses must be read in light of the presumption against preemption; state tort claims survive if they parallel rather than add to or differ from federal requirements.