2026 Membership Book FINAL

Case: 25-1922 Document: 83 Page: 32 Date Filed: 09/24/2025

Page 31

1 agencies. It was not meant to preempt the field. Again, the

2 Seventh Circuit said this in the American Agriculture case.

3 And as we point out in our brief, really, if you're looking at

4 a single statutory provision that's supposed to do some

5 preemption, that's an express preemption argument. They're not

6 arguing express preemption. Nobody has ever argued express

7 preemption here, and we have this Court in Farina rejecting

8 field preemption where an agency in that case, the FCC had

9 exclusive authority to do something.

10

So it's not unprecedented, and when you look at the

11 legislative history for this, you have, you know, legislators

12 saying what we're really concerned about is field preemption,

13 the language they use in the conference report that both

14 parties cite is substantive state laws that are contrary to or

15 inconsistent with federal law are preempted. That's classic

16 conflict preemption.

17

And so I think for those reasons, we would say no

18 field preemption here, and I mentioned the lack of a

19 comprehensive scheme. They don't even try to do that sort of

20 classic field preemption analysis. This is not like, in-air

21 flight operations, or nuclear power plants or anything like

22 that. There's no comprehensive scheme. Kansas versus Garcia

23 tells us these are rare cases of field preemption. This is not

24 one of them.

25

And then lastly, Your Honor, I would just say I guess

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