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Animal Legal Defense Fund v. Reynolds

ELR Citation: 49 ELR 20191
Nos. 4:19-cv-00124-JEG-HCA, (S.D. Iowa, 12/02/2019) (Gritzner, J.)

A district court preliminarily enjoined Iowa from enforcing a statute that criminalized undercover investigations of slaughterhouses and other animal facilities. Environmental groups argued that the state statute impermissibly restricted their free speech under the First Amendment because it was a content- and viewpoint-based restriction that failed to withstand constitutional scrutiny and was overbroad. The state moved to dismiss, asserting that the statute did not cover protected speech because it only prohibited conduct causing legally cognizable harms or made for the purpose of material gain, was not overbroad because it prohibited some but not a substantial amount of speech, and did not impose viewpoint-based discrimination on its face. The court found the groups made a sufficient showing that the statute covered many types of speech that might not cause legally cognizable harms and also prohibited substantially more speech, like that of labor organizers, than the First Amendment permitted. It therefore denied the state's motion to dismiss and preliminarily enjoined the state from enforcing the statute.