On June 25, 2026, the U.S. Supreme Court issued its decision in Monsanto Co. v. Durnell, resolving a dispute over the scope of federal preemption under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. Section 136 et seq. The case presented the question of whether FIFRA preempts a label-based state-law failure-to-warn claim where the U.S. Environmental Protection Agency (EPA) has approved a label that does not require the warning at issue. In a 7-2 decision, the Court held that FIFRA expressly preempts plaintiff’s state-law failure-to-warn claim because it would require Monsanto to add a cancer warning to Roundup’s label.
The decision resolves a circuit split, holding that federal pesticide labels preempt divergent or additional state warning or labeling requirements. It may limit state-law claims against pesticide registrants based on theories of inadequate warning and may provide guidance for pesticide registrants, manufacturers of federally regulated products, and litigants navigating the intersection of federal labeling approvals and state tort law.