In In Monsanto Co. v. Durnell, No. 24–1068 (June 25, 2026), the US Supreme Court issued an important decision addressing the relationship between EPA-approved pesticide labeling and state-law product liability claims. The Court held that the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) expressly preempted state-law failure-to-warn claims that would require pesticide manufacturers to include warnings different from or in addition to those approved by the US Environmental Protection Agency (EPA). The decision resolves a Circuit split regarding the preemptive effect of federal agency labeling decisions.
The majority held that state failure-to-warn tort claims are preempted by federal law and cannot be sustained where they would attempt to impose liability based on information different from or absent from EPA-approved pesticide labels under FIFRA. Justice Clarence Thomas filed a concurring opinion raising constitutional questions concerning the scope of federal regulatory authority under FIFRA. Justice Ketanji Brown Jackson, joined by Justice Neil Gorsuch, dissented, concluding that failure-to-warn tort claims merely paralleled FIFRA’s labeling requirements.
The Supreme Court’s decision resolves Mr. Durnell’s claims that Roundup caused his cancer and clarifies that similar claims based on state failure-to-warn theories are preempted by FIFRA. Although the decision arose from litigation involving Roundup, its significance extends beyond glyphosate-based products. The Court confirmed that, under FIFRA, EPA’s product-specific registration and labeling determinations carry preemptive effect. In doing so, the Court reinforced Congress’s decision to centralize pesticide labeling decisions within EPA and to promote national uniformity through a single federal regulatory framework. The opinion also further aligns FIFRA with the Supreme Court’s broader preemption jurisprudence. By relying extensively on Riegel v. Medtronic, the Court signaled that agency approval decisions may constitute federal requirements where Congress has established a comprehensive regulatory program and directed the agency to make product-specific safety and labeling determinations.