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Court Ruling: Tennessee Walking Horse National Celebration v. USDA

Yesterday, U.S. District Judge Matthew J. Kacsmaryk issued his ruling regarding the Tennessee Walking Horse National Celebration Association (TWHNC), et al. v. United States Department of Agriculture, et al. lawsuit which challenged the new USDA Rule. The case focused on whether the USDA exceeded its authority and whether the new rules complied with due process requirements. Judge Kacsmaryk ruled in favor of TWHNC on all counts except the industry-run Designated Qualified Person (DQP) program.

Although Judge Kacsmaryk ruled in favor of the USDA’s provision eliminating the DQP program, that provision—unless challenged on appeal—would not take effect until April 2, aligning with the 60-day Rule freeze the USDA announced last week. Please note that the new Rule, in its entirety, is still at risk of being completely eliminated with the ushering in of the new Trump administration and/or upcoming Federal appropriations.

Below are the key rulings of the TWHNC v. USDA lawsuit. I’ve also attached the Judge’s full summary judgment.

Key Rulings:

Ban on Action Devices and Pads:

The court ruled that the USDA exceeded its statutory authority by prohibiting action devices, pads, and certain substances used in training and showing Tennessee Walking Horses.

Replacement of the Scar Rule:

The USDA introduced a new standard, the “Dermatologic Conditions Indicative of Soring” (DCIS) rule, to replace the long-standing Scar Rule.

The court found that the new rule lacked clear enforcement guidelines and failed to provide due process protections for horse owners and exhibitors.

Due Process Concerns:

The court determined that the 2024 Rule did not offer adequate pre- and post-deprivation review, making it unconstitutional in terms of enforcement procedures.

This ruling emphasizes that regulatory agencies must ensure fairness in enforcement actions.

Elimination of the DQP Program:

The USDA’s decision to eliminate the industry-run Designated Qualified Person (DQP) program was upheld.

The court found that this action was within the USDA’s authority and was neither arbitrary nor capricious.