Haviland v. Butz case brief

Haviland v. Butz case brief
543 F.2d 169

CASE SYNOPSIS: Appellant citizen sought review of a decision from the United States District Court for the District of Columbia, which granted summary judgment in favor of appellee Secretary of Agriculture (secretary). The citizen had brought an action against the secretary for a judgment declaring that the citizen was not subject to regulation under the Animal Welfare Act of 1970, §§ 20(a), (c), 7 U.S.C.S. §§ 2149(a), (c).

FACTS 

In the view that the citizen, who operated a professional animal act, was an "exhibitor" as defined by the Animal Welfare Act of 1970, 7 U.S.C.S. § 2136, the Department of Agriculture gave notice to the citizen that he was in violation of its licensing provisions. The citizen brought an action against the secretary for a judgment declaring that the citizen was not subject to regulation under the act. 

DISCUSSION

• The district court granted summary judgment in favor of the secretary. 
• The citizen contended that the act, as written and intended, did not embrace animal performances and that the secretary could not expand its coverage. 
• The court held that:
• (1) the statutory listing of covered enterprises was not exhaustive and that the secretary was empowered to promulgate such rules, regulations, and orders as he deemed necessary in order to effectuate the purposes of the statutory scheme; 
• (2) the animal act, traveling from state to state and using facilities of interstate communication, was subject to regulation by Congress in the exercise of the commerce power; 
• (3) the classification effected by the act's definition of "exhibitor" was rationally related to a legitimate governmental interest.

CONCLUSION: Secretary of Agriculture was entitled to summary judgment in the citizen's action for a declaratory judgment that the citizen, who operated a professional animal act, was not subject to regulation under the federal Animal Welfare Act.