Monsanto v. Durnell
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Monsanto v. Durnell and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Monsanto v. Durnell.
The Supreme Court ruled that the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) preempts state-law failure-to-warn claims that require additional labeling for pesticides like Roundup. The Court found that FIFRA's preemption clause prevents states from imposing labeling requirements different from federal standards. This decision reversed the Missouri Court of Appeals' ruling in favor of John Durnell.
Holding
The single most important “bottom line” of what the Court decided in Monsanto v. Durnell.
The Court held that FIFRA expressly preempts Durnell’s state-law failure-to-warn claim because it would require Monsanto to add a cancer warning to Roundup’s label.
Constitutional Concepts
These are the Constitution-related themes that appear in Monsanto v. Durnell. Click a concept to see other cases that involve the same idea.
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Why Preemption is relevant to Monsanto v. Durnell
The Court's holding is based on the principle that federal law, specifically FIFRA, preempts state law claims that impose additional labeling requirements.
Syllabus excerpt (verbatim)FIFRA expressly preempts Durnell’s state-law failure-to-warn claim because the claim would require Monsanto to add a cancer warning to Roundup’s label.
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Why Administrative Law is relevant to Monsanto v. Durnell
The case involves the EPA's authority and role in approving pesticide labels, which is central to the Court's analysis of FIFRA's preemption.
Syllabus excerpt (verbatim)EPA must approve the pesticide’s label by determining that the label contains all warnings 'necessary and . . . adequate to protect health and the environment.'
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Why State–Federal Power is relevant to Monsanto v. Durnell
The case addresses the allocation of authority between state and federal governments regarding pesticide labeling requirements.
Syllabus excerpt (verbatim)FIFRA therefore preempts a state-law labeling requirement that differs from the federal labeling requirements imposed under FIFRA.
Key Quotes
Short excerpts from the syllabus in Monsanto v. Durnell that support the summary and concepts above.
FIFRA expressly preempts Durnell’s state-law failure-to-warn claim because the claim would require Monsanto to add a cancer warning to Roundup’s label.
Federal law therefore requires Monsanto to sell Roundup with the label that EPA approved at the initial registration.
Durnell’s state tort claim would require Monsanto to add a cancer warning to its labels, which is 'in addition to' and 'different from' Monsanto’s federal-law labeling obligations.