California Supreme Court: State-law suit alleging food is mislabled as “organic” is not federally preempted

The decision in Quesada v. Herb Thyme Farms is here.

Here's a brief excerpt from the beginning of the opinion that sets the scene and summarizes the holding:

To buyers and sellers alike "labels matter." (Kwikset Corp. v. Superior Court (2011) 51 Cal.4th 310, 328.) They serve as markers for a host of tangible and intangible qualities consumers may come to associate with a particular source or method of production. ( pp. 328–329.) Misrepresentations in labeling undermine this signifying function, preventing consumers from correctly identifying the goods and services that carry the attributes they desire while also hampering honest producers‘ attempts to differentiate their merchandise from the competition.
Among those labels Kwikset cited as making a difference to some consumers, and as potentially actionable under state unfair competition law if misused, was the designation of produce or other food as "organic." (Kwikset Corp. v. Superior Court, supra, 51 Cal.4th at pp. 332–333.) Here we must decide whether such a state law claim is viable, or whether the federal regulatory regime for certifying organic growers preempts a state claim that a certified grower is intentionally mislabeling conventionally grown produce and selling it as "organic."
We hold a state law claim that produce is being intentionally mislabeled as organic is not preempted. When Congress entered the field in 1990, it confined the areas of state law expressly preempted to matters related to certifying production as organic, leaving untouched enforcement against abuse of the label "organic." Moreover, a central purpose behind adopting a clear national definition of organic production was to permit consumers to rely on organic labels and curtail fraud. Accordingly, state lawsuits alleging intentional organic mislabeling promote, rather than hinder, Congress‘s purposes and objectives. Because the Court of Appeal concluded to the contrary, finding these state fraud claims impliedly preempted, we reverse its judgment.

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