Case: Przybocki v. United States Department of Agriculture

2:23-cv-00455 | U.S. District Court for the District of Nevada

Filed Date: March 28, 2023

Case Ongoing

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Case Summary

            This is a case about the free speech implications of government restrictions on the labels of various packaged foods. On March 28, 2023, a business owner, his business, and a customer of his business sued the U.S. Department of Agriculture (USDA), its Food Safety and Inspection Service (FSIS) and the Food and Drug Administration (FDA)  in the U.S. District Court for the District of Nevada. Represented by local counsel as well as the Institute for Justice, the Plaintiffs sued for vio…

            This is a case about the free speech implications of government restrictions on the labels of various packaged foods. On March 28, 2023, a business owner, his business, and a customer of his business sued the U.S. Department of Agriculture (USDA), its Food Safety and Inspection Service (FSIS) and the Food and Drug Administration (FDA)  in the U.S. District Court for the District of Nevada. Represented by local counsel as well as the Institute for Justice, the Plaintiffs sued for violations of the First Amendment and sought declaratory relief, an injunction lifting the ban on their desired labeling, attorneys fees, and any other legal or equitable relief the court deemed fair. The case was assigned to Judge Anne R. Traum and Magistrate Judge Daniel J. Albregts. 

            The business owner and his company allege that FSIS required them to remove terms such as “low-FODMAP” (an acronym for items low in various difficult-to-digest sugars), “deliciously digestible,” and “gut loving” from their product labels. They further allege that the removal violated their First Amendment rights because the statements, while allegedly verifiable and non-misleading, were ultimately impermissible. FSIS and FDA permit claims such as these only if they are defined in their regulations and included on a pre-approved list of similar nutrient content claims (for example, the agencies maintain established standards for what counts as “low sodium,” but not what count as “low-FODMAP”). Consequently, plaintiffs allege that this “pre-approved and exclusive” list of statements violates the First Amendment because it excludes otherwise true and verifiable information that consumers, such as the consumer-plaintiff in this case, might want to know. 

On June 23, 2023, defendants filed a motion to dismiss, which the plaintiffs responded to on August 18, 2023. The case is ongoing. 

Summary Authors

Alex Levin (1/3/2024)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/67110468/parties/przybocki-v-united-states-department-of-agriculture/


Attorney for Plaintiff

Dushoff, Matthew T (Nevada)

Pearson, Justin (Nevada)

Sanz, Elizabeth L. (Nevada)

Sherman, Paul M. (Nevada)

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Documents in the Clearinghouse

Document
1

2:23-cv-00455

Complaint for Declaratory and Injunctive Relief

March 28, 2023

March 28, 2023

Complaint

Docket

See docket on RECAP: https://www.courtlistener.com/docket/67110468/przybocki-v-united-states-department-of-agriculture/

Last updated March 19, 2024, 3:06 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against All Defendants (Filing fee $402 receipt number ANVDC-7248975) by Gourmend Foods, LLC, Ketan Vakil, Michelle Przybocki. Certificate of Interested Parties due by 4/7/2023. Proof of service due by 6/26/2023. (Attachments: # 1 Civil Cover Sheet, # 2 Summons U.S. Department of Agriculture, # 3 Summons U.S. Department of Agriculture via U.S. Attorney General, # 4 Summons U.S. Department of Agriculture via U.S. Attorney's Office, # 5 Summons Thomas J. Vilsack in his official capacity as Secretary of Agriculture, # 6 Summons Thomas J. Vilsack via U.S. Attorney General, # 7 Summons Thomas J. Vilsack via U.S. Attorney's Office, # 8 Summons U.S. Department of Ag. FSIS, # 9 Summons U.S. Department of Ag. FSIS via U.S. Attorney Genera, # 10 Summons U.S. Department of Ag. FSIS via U.S. Attorney's Office, # 11 Summons Sandra Eskin, in her official capacity as U.S. Deputy Under Secretary for Food Safety, # 12 Summons Sandra Eskin via U.S. Attorney General, # 13 Summons Sandra Eskin via U.S. Attorney's Office, # 14 Summons U.S. Food and Drug Administration, # 15 Summons U.S. Food and Drug Administration via U.S. Attorney General, # 16 Summons U.S. Food and Drug Administration via U.S. Attorney's Office, # 17 Summons Robert Califf, in his official capacity as Commissioner, # 18 Summons Robert Califf via U.S. Attorney General, # 19 Summons Robert Califf via U.S. Attorney's Office) (Dushoff, Matthew) NOTICE of Certificate of Interested Parties requirement: Under Local Rule 7.1-1, a party must immediately file its disclosure statement with its first appearance, pleading, petition, motion, response, or other request addressed to the court. (Entered: 03/28/2023)

1 Civil Cover Sheet

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2 Summons U.S. Department of Agriculture

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3 Summons U.S. Department of Agriculture via U.S. Attorney General

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4 Summons U.S. Department of Agriculture via U.S. Attorney's Office

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5 Summons Thomas J. Vilsack in his official capacity as Secretary of Agriculture

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6 Summons Thomas J. Vilsack via U.S. Attorney General

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7 Summons Thomas J. Vilsack via U.S. Attorney's Office

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8 Summons U.S. Department of Ag. FSIS

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9 Summons U.S. Department of Ag. FSIS via U.S. Attorney Genera

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10 Summons U.S. Department of Ag. FSIS via U.S. Attorney's Office

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11 Summons Sandra Eskin, in her official capacity as U.S. Deputy Under Secretary fo

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12 Summons Sandra Eskin via U.S. Attorney General

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13 Summons Sandra Eskin via U.S. Attorney's Office

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14 Summons U.S. Food and Drug Administration

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15 Summons U.S. Food and Drug Administration via U.S. Attorney General

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16 Summons U.S. Food and Drug Administration via U.S. Attorney's Office

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17 Summons Robert Califf, in his official capacity as Commissioner

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18 Summons Robert Califf via U.S. Attorney General

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19 Summons Robert Califf via U.S. Attorney's Office

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March 28, 2023

March 28, 2023

Clearinghouse
2

CERTIFICATE of Interested Parties by Gourmend Foods, LLC, Michelle Przybocki, Ketan Vakil. There are no known interested parties other than those participating in the case. (Dushoff, Matthew) (Entered: 03/28/2023)

March 28, 2023

March 28, 2023

PACER
3

MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Paul M. Sherman and DESIGNATION of Local Counsel Matthew T. Dushoff (Filing fee $ 250 receipt number ANVDC-7249095) by Plaintiffs Gourmend Foods, LLC, Michelle Przybocki, Ketan Vakil. (Dushoff, Matthew) (Entered: 03/28/2023)

March 28, 2023

March 28, 2023

PACER
4

MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Justin M. Pearson and DESIGNATION of Local Counsel Matthew T. Dushoff (Filing fee $ 250 receipt number ANVDC-7249111) by Plaintiffs Gourmend Foods, LLC, Michelle Przybocki, Ketan Vakil. (Dushoff, Matthew) (Entered: 03/28/2023)

March 28, 2023

March 28, 2023

PACER
5

MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Elizabeth L. Sanz and DESIGNATION of Local Counsel Matthew T. Dushoff (Filing fee $ 250 receipt number ANVDC-7249137) by Plaintiffs Gourmend Foods, LLC, Michelle Przybocki, Ketan Vakil. (Dushoff, Matthew) (Entered: 03/28/2023)

March 28, 2023

March 28, 2023

PACER

Case randomly assigned to District Judge Anne R. Traum and Magistrate Judge Daniel J. Albregts. (HAM)

March 28, 2023

March 28, 2023

PACER
6

SUMMONS ISSUED re 1 Complaint (HAM) (Entered: 03/28/2023)

March 28, 2023

March 28, 2023

PACER
7

ORDER APPROVING ECF No. 3 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Paul M. Sherman for Michelle Przybocki and approving Designation of Local Counsel Matthew T. Dushoff. Signed by District Judge Anne R. Traum on 3/29/2023. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website www.pacer.gov(Copies have been distributed pursuant to the NEF - DLS) (Entered: 03/30/2023)

March 29, 2023

March 29, 2023

PACER
8

ORDER APPROVING ECF No. 4 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Justin M. Pearson for Michelle Przybocki and approving Designation of Local Counsel Matthew T. Dushoff. Signed by District Judge Anne R. Traum on 3/29/2023. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website www.pacer.gov(Copies have been distributed pursuant to the NEF - DLS) (Entered: 03/30/2023)

March 29, 2023

March 29, 2023

PACER
9

ORDER APPROVING ECF No. 5 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Elizabeth L. Sanz for Gourmend Foods, LLC, Michelle Przybocki, and Ketan Vakil and approving Designation of Local Counsel Matthew T. Dushoff. Signed by District Judge Anne R. Traum on 3/29/2023. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website www.pacer.gov(Copies have been distributed pursuant to the NEF - DLS) (Entered: 03/30/2023)

March 29, 2023

March 29, 2023

PACER
10

CLERK'S NOTICE Regarding Local Rule IC 2-1. Attorney Paul M. Sherman is in violation of Local Rule IC 2-1(a) and 2-1(d). You are required to register to file documents electronically in the Court's electronic filing system (CM/ECF) and the electronic service of pleadings and other papers. Please visit the PACER website www.pacer.gov to complete the registration. (no image attached) (WJ) (Entered: 03/31/2023)

March 31, 2023

March 31, 2023

PACER
11

CLERK'S NOTICE Regarding Local Rule IC 2-1. Attorney Justin M. Pearson is in violation of Local Rule IC 2-1(a) and 2-1(d). You are required to register to file documents electronically in the Court's electronic filing system (CM/ECF) and the electronic service of pleadings and other papers. Please visit the PACER website www.pacer.gov to complete the registration. (no image attached) (WJ) (Entered: 03/31/2023)

March 31, 2023

March 31, 2023

PACER
12

CLERK'S NOTICE Regarding Local Rule IC 2-1. Attorney Elizabeth L. Sanz is in violation of Local Rule IC 2-1(a) and 2-1(d). You are required to register to file documents electronically in the Court's electronic filing system (CM/ECF) and the electronic service of pleadings and other papers. Please visit the PACER website www.pacer.gov to complete the registration. (no image attached) (WJ) (Entered: 03/31/2023)

March 31, 2023

March 31, 2023

PACER
32

Order on Motion to Admit Government Attorney

April 25, 2023

April 25, 2023

PACER
34

Order AND Order on Stipulation AND ~Util - Set/Reset Deadlines & Hearings (non motion deadlines)

June 5, 2023

June 5, 2023

PACER
36

ORDER granting 35 Stipulation To Extend Time for Defendants To Respond to the Complaint and for Plaintiffs To File Opposition. Defendants deadline to file their anticipated motion to dismiss the complaint is extended from June 16, 2023, to June 23, 2023. This is the final extension that Defendants will receive for their motion and opening brief. Plaintiffs deadline to oppose Defendants anticipated motion to dismiss is extended from July 20, 2023, to August 4, 2023. Signed by District Judge Anne R. Traum on 6/16/2023. (Copies have been distributed pursuant to the NEF - CAH)

June 16, 2023

June 16, 2023

RECAP
37

Motion Dismiss

June 23, 2023

June 23, 2023

PACER
38

Stipulation

July 24, 2023

July 24, 2023

PACER
39

ORDER granting 38 Stipulation to Extend Time for Plaintiffs to Respond to Defendants' 37 Motion to Dismiss and Defendants to File Reply. Responses due by 8/18/2023. Replies due by 9/18/2023. Signed by District Judge Anne R. Traum on 7/24/2023. (Copies have been distributed pursuant to the NEF - CT)

July 24, 2023

July 24, 2023

RECAP
40

Response

Aug. 18, 2023

Aug. 18, 2023

PACER
41

Stipulation

Sept. 13, 2023

Sept. 13, 2023

PACER
42

Order on Stipulation

Sept. 14, 2023

Sept. 14, 2023

PACER
43

Reply

Sept. 18, 2023

Sept. 18, 2023

PACER

Case Details

State / Territory: Nevada

Case Type(s):

Public Benefits/Government Services

Speech and Religious Freedom

Key Dates

Filing Date: March 28, 2023

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

A business owner and customer seeking to disseminate and receive, respectively, information about easily-digestible food products.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Institute for Justice

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

U.S. Department of Agriculture (Washington, District of Columbia), Federal

Food and Drug Administration (FDA) (Silver Spring, Maryland), Federal

United States Department of Agriculture's Food Safety and Inspection Service (FSIS) (Washington, District of Columbia), Federal

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

Declaratory Judgment Act, 28 U.S.C. § 2201

Ex parte Young (federal or state officials)

Constitutional Clause(s):

Freedom of speech/association

Available Documents:

Trial Court Docket

Complaint (any)

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None yet

Source of Relief:

None yet

Issues

General/Misc.:

Classification / placement

Government services