utah ag gag lawsuit response

8/11/2019 Utah Ag Gag lawsuit response

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KYLE J. KAISER (13924)DANIEL R. WIDDISON (11979)

Utah Attorneys General

Attorneys for Defendants160 East 300 South, Sixth Floor

P.O. Box 140856

Salt Lake City, Utah 84114-0856

Telephone: (801) 366-0100Facsimile: (801) 366-0101

E-mail: [email protected]

E-mail:[email protected]

IN THE UNITED STATES DISTRICT COURT

IN AND FOR THE DISTRICT OF UTAH, CENTRAL DIVISION

ANIMAL LEGAL DEFENSE FUND,

PEOPLE FOR THE ETHICAL TREATMENT

OF ANIMALS, COUNTERPUNCH, AMY

MEYER, WILL POSTTER, DANIELHAUFF, JAMES McWILLIAMS, JESSE

FRUHWIRTH,

Plaintiff,

v.

GARY R. HERBERT, in his official capacity

as Governor of Utah; SEAN D. REYES, in his

official capacity as Attorney General of Utah,

Defendants.

DEFENDANTS ANSWER TO CIVIL

RIGHTS COMPLAINT

Case No. 2:13-cv-00679-RJSJudge: Robert J. Shelby

Defendants Gary R. Herbert and Sean D. Reyes (Defendants) answer the Complaint

filed by Plaintiffs and assert defenses as follows:1

1 Unless specifically admitted herein, Defendants deny each and every allegation of

Plaintiffs Complaint.

Case 2:13-cv-00679-RJS Document 60 Filed 09/08/14 Page 1 of 25
mailto:[email protected]:[email protected]:[email protected]:[email protected]


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PLAINTIFFS INTRODUCTION

1.

Paragraph 1 is a legal conclusion to which no response is required. To the extent

a response is required, Defendants deny Plaintiffs characterization of Utah Code 76-6-112

(hereinafter, the Act) that Plaintiffs Complaint states a cause of action as alleged or that any

Plaintiffs are entitled to any relief.

2. Defendants admit that Upton Sinclairs book, The Jungle, predated the enactment

of the Federal Meat Inspection Act and the Pure Food and Drug act; Defendants deny the

allegation in all other respects.

3. Defendants deny the allegations in Paragraph 3. Regarding footnote 1,

Defendants admit that undercover investigations have occurred at agricultural operations in other

states and selected operations have received media attention. Defendants lack information

sufficient to form a belief about the further allegations in footnote 1, and therefore deny the

same.

4. Paragraph 4 is a legal conclusion to which no response is required. To the extent

a response is required, Defendants deny that the purpose of the Act is to gag speech that is

critical of industrial agriculture,deny Plaintiffs Complaint states a cause of action as alleged,

and deny that any Plaintiffs are entitled to any relief.

5.

Paragraph 5 is an irrelevant statement of Plaintiffs purposeto which no response

is required. To the extent a response is required, Defendants admit that the Act reads as stated in

footnote 2 and deny the allegations in all other respects.

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6. As to the allegations in Paragraph 6, Defendants admit that federal crimes relating

to food safety and animal handling, in general, exist; Defendants deny the remaining allegations

of Paragraph 6.


a response is required, Defendants deny the allegations.



9.

Paragraph 9 is a legal conclusion to which no response is required. To the extent


10. Defendants lack information sufficient to form a belief as to the truth of the

allegations in the first and second sentences of Paragraph 10, and therefore deny the same.

Defendants deny the allegations in the third sentence of Paragraph 10.

11. The allegation of Paragraph 11 relates to Plaintiffs Third Cause of Action which

was dismissed. See Minute Entry, Docket # 54. To the extent a response is necessary,

Defendants deny the allegation.


a response is required, Defendants deny the allegation.


a response is required, Defendants deny the allegation.

14. Paragraph 14 is a request for legal relief, to which no response is required. To the

extent a response is required, Defendants deny that Plaintiffs Complaint states a cause of action

as alleged or that any Plaintiffs are entitled to any relief.



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a response is required, Defendants deny that Plaintiffs Complaint states a cause of action as

alleged or that any Plaintiffs are entitled to any relief.

JURISDICTION AND VENUE

16. As to the allegations in Paragraph 16, Defendants admit that Plaintiffs seek a

declaration to enforce the United States Constitution and laws of the United States including

42 U.S.C. 1983 and 1988 and admit that jurisdiction is proper in this Court pursuant to

28 U.S.C. 1331 and 1343.

17. As to the allegations in Paragraph 17, Defendants admit that the rules and statutes

cited in Paragraph 17 authorize a court to provide relief, but deny that Plaintiffs are entitled to

such relief.

18. As to the allegations in Paragraph 18, Defendants admit that venue is proper in

the Central District of Utah.

PARTIES

PLAINTIFFS


allegations in Paragraph 19, and therefore deny the same.



21. As to the allegations in Paragraph 21, Defendants affirmatively assert that

Plaintiff COUNTERPUNCH was dismissed from this lawsuitby the Courts Order dated August

8, 2014 and is no longer a party, and therefore no response is required. SeeMinute Entry, Docket

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# 54. To the extent a response is required, Defendants lack sufficient knowledge to admit or

deny the allegations in Paragraph 21 and therefore deny the same.

22. As to the allegations in Paragraph 22, Defendants admit that Plaintiff Meyer was

criminally charged for violating the Act, and such charges were dismissed without prejudice.

Defendants lack information sufficient to form a belief as to the truth of the remaining



Plaintiff WILL POTTER was dismissed from this lawsuit by the Courts Order dated August 8,

2014 and is no longer a party, and therefore no response is necessary. SeeMinute Entry, Docket

# 54. To the extent a response is necessary, Defendants lack information sufficient to form a

belief as to the truth of the allegations in Paragraph 23, and therefore deny the same.




Plaintiff JAMES MCWILLIAMS was dismissed from this lawsuit by the Courts Order da ted

August 8, 2014 and is no longer a party, and therefore no response is necessary. See Minute

Entry, Docket # 54. To the extent a response is necessary, Defendants lack information

sufficient to form a belief as to the truth of the allegations in Paragraph 25, and therefore deny

the same.


Plaintiff JESSE FRUHWIRTH was dismissed from this lawsuit by the Court s Order dated

August 8, 2014 and is no longer a party. See Minute Entry, Docket # 54. To the extent a



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response is necessary, Defendants lack information sufficient to form a belief as to the truth of

the allegations in Paragraph 26, and therefore deny the same.

DEFENDANTS

27. Defendants admit the allegations in Paragraph 27.

28. Defendants deny that JOHN SWALLOW is the Attorney General of Utah and

affirmatively assert that SEAN D. REYES is the Attorney General of Utah and admit the

remaining allegations contained in Paragraph 28.

FACTUAL BACKGROUND

Statutory Overview

29.

Defendants admit the allegations in Paragraph 29 and assert that the text of the

Act is plain.

30. Defendants admit that Paragraph 30 contains an accurate quotation of a portion of

the Act. Defendants deny any further allegations contained in Paragraph 30.

31. Defendants admit that Paragraph 31(a)-(d) contain accurate quotations of portions

of the Act. Defendants deny all remaining allegations in Paragraph 31, including, but not limited

to, that the statute in any way limits whistle-blowing activity.

32. As to the allegations in Paragraph 32, Defendants admit that a person who

commits agriculture operation inference is subject to a Class A or Class B Misdemeanor as

outlined in the Act. Defendants deny any further allegations, including the irrelevant comparison

stated in Paragraph 32 with regard to the same penalty as would attach to assaulting a police

officer,and the allegation in footnote 4.



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33. Paragraph 33 states a legal conclusion to which no response is required. To the

extent a response is required, Defendants lack information sufficient to form a belief about the

type of investigations contemplated by Animal Legal Defense Fund (ALDF)and People for

the Ethical Treatment of Animals (PETA), and therefore deny the same. Defendants deny any

remaining allegations in Paragraph 33.

34. As to the allegations in Paragraph 34, Defendants lack information sufficient to

form a belief as to the truth of the first clause of the sentence, and therefore deny the same.

Defendants deny the allegation in the second clause of Paragraph 34.


extent a response is required, Defendants deny the allegations in Paragraph 35.

36. Defendants deny the allegations in Paragraph 36.

Statutory Purpose

37. As to the allegations in Paragraph 37, Defendants admit that one violates

subsection 2(a) of the Act only if the person knowingly or intentionally records an image of, or

sound from, the agricultural operation by leaving a recording device on the agricultural

operationwithout the consent of the owner of the agricultural operation, or the owners

agent, and that a person violations subsection 2(d) of the act if a person records images or

sounds from an agricultural operation while committing a criminal trespass, without the consent

from the owner or the owners agent. Defendants deny any remaining allegations in

Paragraph 37.



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extent a response is required, Defendants deny the allegations in Paragraph 38, including the

allegation that the statute criminalizes recording based on the content recorded.




extent a response is required, Defendants deny the allegations in Paragraph 40, including the

allegation that the statute criminalizes the production of speech.


42. Defendants admit that Paragraph 42 contains select, out-of-context quotations by

a Utah state legislator. Defendants deny any further allegations in the paragraph, including that

such a quotation is relevant to the constitutionality of the Act.



such a quotation is relevant to the constitutionality of the Act, or that the legislator had disdain

for animal protection organizations.









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such a quotation is relevant to the constitutionality of the Act. Defendants further object to the

characterization of a representatives floor testimony through the use of an on-line slang

dictionary, and denies the allegations in footnote 5. Defendants deny the final sentence of

Paragraph 46.



such a quotation is relevant to the constitutionality of the Act, or that the legislator provided a

litany of personal, animus-based objections to PETAs lawful activity.



such a quotation is relevant to the constitutionality of the Act, or that Plaintiffs viewpoints are

not entitled to protection.

49. Defendants lack the information sufficient to form a belief as to the allegations in

Paragraph 49, and therefore deny the same.






such a quotation is relevant to the constitutionality of the Act, or that Plaintiffs have been labeled



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as animal rights terrorists. Defendants deny the allegation in footnote 7 that the Act is

grounded in animus.



such a quotation is relevant to the constitutionality of the Act and that Plaintiffs are misguided.

53. Defendants lack sufficient information to form a belief about the truth of the


54.

Defendants lack sufficient information to form a belief about the truth of the











Investigations and Reporting Generally

60. Defendants lack information sufficient to form a belief about the truth of the




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Plaintiffs Potter, CounterPunch, McWilliams, and Fruhwirth were dismissed from this lawsuit by

the Courts Order dated August 8, 2014 and are no longer parties, and therefore no response is

necessary. See Minute Entry, Docket # 54. To the extent a response is necessary, Defendants

lack information sufficient to form a belief as to the truth of the allegations in Paragraph 61.



63.

Defendants lack information sufficient to form a belief about the truth of the










68. Defendants lack sufficient knowledge and information to admit or deny the

allegations in paragraph 68 and, therefore, deny the same.





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allegations in paragraph 71 and, therefore, deny the same.



State Speech Regarding Animal Agriculture

73.

Defendants deny the allegations in Paragraph 73.


75. Defendants deny that the Utah Department of Agriculture and Food (UDAF)

currently posts a series of videos entitled Agriculture 101 on its website,

http://www.ag.utah.gov,but admits that videos produced over the last number of years by the

Department are available for viewing at online athttp://www.youtube.com/user/UtahAgriculture.

Defendants lack information sufficient to form a belief about the truth of any remaining


76. Defendants admit that a video, entitled Why Utah Eggs Are Safe appears as

uploaded to YouTube by the Department on September 4, 2010. Defendants deny that the video

has any relevance to Plaintiffs claims, and deny any further allegations contained in

Paragraph 76.

a. Defendants admit that Paragraph 76(a) includes accurate, partial quotations from

the video presented without context. Defendants deny that the quotation has any

http://www.ag.utah.gov/http://www.ag.utah.gov/http://www.youtube.com/user/UtahAgriculturehttp://www.youtube.com/user/UtahAgriculturehttp://www.youtube.com/user/UtahAgriculturehttp://www.youtube.com/user/UtahAgriculturehttp://www.ag.utah.gov/


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relevance to Plaintiffs claims, and deny any further allegations contained in

Paragraph 76(a).

b. Defendants admit that Paragraph 76(b) includes accurate, partial quotations from



Paragraph 76(b).

c. Defendants admit that Paragraph 76(c) includes accurate, partial quotations from



Paragraph 76(c).

d. Defendants admit that Paragraph 76(d) includes a reference to certain video

footage in the video. Defendants deny that the quotation has any relevance to

Plaintiffs claims, and deny any further allegations contained in Paragraph 76(d).

e. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 76(e), and therefore deny the same.

f. Defendants admit that the voters of California passed a proposition in 2008

prohibiting cages in which animals cannot stretch their limbs, but the statute

resulting from the proposition does not take effect until January 1, 2015.


allegations in Paragraph 76(f), and therefore deny the same.

g. Defendants deny the allegations in paragraph 76(g).



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allegations in Paragraph 77, and therefore deny the same. To the extent such a video exists,

Defendants deny that the video has any relevance to Plaintiffs claims, and deny any further

allegations contained in Paragraph 77.

a. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 77(a), and therefore deny the same.

b. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 77(b), and therefore deny the same.

c. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 77(c), and therefore deny the same.

d. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 77(d), and therefore deny the same.



f. Defendants lack information sufficient to form a belief about the truth of the


g. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 77(g), and therefore deny the same.

h.

Defendants deny the allegations in Paragraph 77(h).


allegations in Paragraph 78, and therefore deny the same. To the extent such a video exists,



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Defendants deny that the video has any relevance to Plaintiffs claims, and deny any further

allegations contained in Paragraph 78.

a. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 78(a), and therefore deny the same.

b. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 78(b), and therefore deny the same.

c. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 78(c), and therefore deny the same.

d. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 78(d), and therefore deny the same.



f. Defendants lack information sufficient to form a belief about the truth of the


g. Defendants lack information sufficient to form a belief about the truth of the

allegations in Paragraph 78(g), and therefore deny the same.

h. Defendants deny the allegations in Paragraph 78(h).


allegations in paragraph 79 and, therefore, deny the same. Defendants assert that the Learn

About Agriculture, Links of Interest has been moved to http://ag.utah.gov/learn-ag.html.

Defendants deny that the website links have any relevance to Plaintiffs claims, and deny any

further allegations contained in Paragraph 79.

http://ag.utah.gov/learn-ag.htmlhttp://ag.utah.gov/learn-ag.htmlhttp://ag.utah.gov/learn-ag.html


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a. Defendants admit that a link to the website of the Animal Agriculture Alliance, is

located athttp://ag.utah.gov/learn-ag.htmland the content of the page located at

the link speaks for itself. Defendants deny the remaining allegations in paragraph

79(a).

b. Defendants lack sufficient knowledge and information to admit or deny the

allegations in paragraph 79(b) and, therefore, deny the same.

c. Defendants lack sufficient knowledge and information to admit or deny the

allegations in paragraph 79(c) and, therefore, deny the same.

d. Defendants admit that a link to the website, I Love Farmers, is located at

http://ag.utah.gov/learn-ag.htmland lack sufficient knowledge and information to

admit or deny the remaining allegations in paragraph 79(d) and, therefore, deny

the same.

e. Defendants deny the allegations in paragraph 79(e).


extent a response is required, Defendants admit that the Department of Agriculture is free to

promote agriculture and deny the remaining allegations in Paragraph 80.

Investigative Interests





http://ag.utah.gov/learn-ag.htmlhttp://ag.utah.gov/learn-ag.htmlhttp://ag.utah.gov/learn-ag.htmlhttp://ag.utah.gov/learn-ag.htmlhttp://ag.utah.gov/learn-ag.htmlhttp://ag.utah.gov/learn-ag.htmlhttp://ag.utah.gov/learn-ag.html


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87.

















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96. Defendants admit that Defendants have not instructed prosecutors in Utah to

refuse to enforce Utah Code Ann. 76-6-112. Defendants deny all remaining allegations in

Paragraph 96.

97.




99. Defendants deny the allegations in paragraph 99.

Reporter and Scholarly Interests

100. Regarding Paragraphs 100104, Defendants affirmatively assert that Plaintiffs

Potter, CounterPunch, McWilliams, and Fruhwirth were dismissed from this lawsuit by the

Courts Order dated August 8, 2014 and are no longer parties, and therefore no response is

necessary. See Minute Entry, Docket # 54. To the extent a response is necessary, Defendants

deny these dismissed Plaintiffs state a cause of action or that the Act is unconstitutional.

Fear of Arrest or Prosecution for Lawful Conduct

105.






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107. Defendants admit that Meyer was charged with violation of the Act and lack

information sufficient to form a belief about the truth of the allegations in Paragraph 107, and

therefore deny the same.

108. Defendants admit that the charges against Meyer were dismissed and lack

information sufficient to form a belief about the truth of the allegations in Paragraph 108, and

therefore deny the same.


CLAIMS FOR RELIEF

Declaratory Relief

110. The allegations in paragraph 110 contain legal conclusions to which no response

is required. To the extent a response is required, Defendants admit that Plaintiffs contend that

Utah Code Ann. 76-6-112is unconstitutional.


Injunctive Relief


FIRST CAUSE OF ACTION

(First Amendment: Overbreadth)

113. Defendants incorporate by reference all preceding responses and defenses to


114. The allegations in Paragraph 114 contain legal conclusions to which no response

is required. To the extent a response is required, Defendants deny the allegations in

Paragraph 114.



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is required. To the extent a response is required, Defendants admit that the concept of

overbreadth has been recognized by the United States Supreme Court but deny that the Act is

overbroad.



Paragraph 116.

117.








SECOND CAUSE OF ACTION

(First Amendment: Content & Viewpoint Based Discrimination)




is required. To the extent a response is required, Defendants admit that the United States

Supreme Court has recognized that laws which discriminate based on their content and

viewpoint are entitled to heightened scrutiny under the First Amendment. Defendants deny that



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the Act constitutes content- or viewpoint-based discrimination, and deny all remaining

allegations in Paragraph 125.
















131. The allegations in Paragraph 131 are vague and conclusory, and therefore no

response is required. To the extent a response is required, Defendants admit that the Act is

limited to enforcement on agricultural operations, but deny any remaining allegations in

Paragraph 131.



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Paragraph 132.


is required. To the extent a response is required, Defendants deny that the compelling interest

test is the appropriate level of review of the Act, and deny all remaining allegations in

Paragraph 133.

134.



THIRD CAUSE OF ACTION

(Article VI, 2: Supremacy Clause: Preemption)



137.

Regarding Paragraphs 137146, Defendants affirmatively assert that Plaintiffs

Third Cause of Action was dismissed from this lawsuit by the Courts Order dated August 8,

2014, and therefore no response is necessary. See Minute Entry, Docket # 54. To the extent a

response is necessary, Defendants deny that Plaintiffs have stated a claim and deny all other

allegations made in Paragraph 137146.

FOURTH CAUSE OF ACTION

(Fourteenth Amendment: Equal Protection & Due Process)





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148. The allegations in Paragraph 148 state a legal conclusion to which no response is

required. To the extent a response is required, Defendants admit that Paragraph 148 contains a

quotation from the Fourteenth Amendment to the United States Constitution.

149. The allegations in paragraph 149 state a legal conclusion to which no response is

required. To the extent a response is required, Defendants deny that animus alone can invalidate

a statute, and deny that the Act was enacted based on animus.


151.



PLAINTIFFS RELIEF REQUESTED

Defendants deny that Plaintiffs are entitled to any relief as listed in paragraphs 153157

of the section of plaintiffs Complaint entitled PRAYER FOR RELIEF.

AFFIRMATIVE DEFENSES

FIRST DEFENSE

Plaintiffs Complaint fails to state a claim for relief.

SECOND DEFENSE

Defendants are entitled to qualified immunity to the extent Plaintiffs seek monetary

damages.

THIRD DEFENSE

Plaintiffs claims are foreclosed by the Eleventh Amendment, sovereign immunity,

governmental immunity, or are subject to or barred by the provisions of the Governmental

Immunity Act of Utah, Utah Code Ann. 63-30(d)-101, et seq.



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FOURTH DEFENSE

Plaintiffs lack standing to bring their claims.

FIFTH DEFENSE

Upon information and belief, Plaintiffs claims are barred by the doctrine of unclean

hands.

SIXTH DEFENSE

The Act does not restrict speech on its face, and, to the extent the Act incidentally affects

Plaintiffs expression, it is not unduly restrictive of any of Plaintiffs expression.

SEVENTH DEFENSE

Defendants preserve and do not waive any of the affirmative defenses set forth in Rule

8(c) of the Federal Rules of Civil Procedure,as discovery may reveal to be applicable, or any

other matter constituting an affirmative defense as may become known in the future.

JURY DEMAND

Defendants demand a trial by jury on all issues so triable.

PRAYER

WHEREFORE, Defendants Gary R. Herbert and Sean D. Reyes, respectfully pray that

the Court enter judgment dismissing Plaintiffs Complaint with prejudice, that Plaintiffs take

nothing, and that the Court award Defendants their costs incurred and such other relief as the

Court deems just.

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DATED: September 9, 2014

OFFICE OF THE UTAH ATTORNEY GENERAL

/s/ Daniel R. Widdison

KYLE J. KAISER

DANIEL R. WIDDISONAssistant Utah Attorneys General

Attorneys for Defendants


utah ag gag lawsuit response

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