welfare practices

The core of foie gras production is the gavage (force-feeding) process, and from 1990s through 2004 the U.S. producers largely followed standard foie gras husbandry similar to European farms, with some claimed improvements. Gavage Schedule: Ducks were typically force-fed for two to three weeks, 2–3 times per day[37]. A common schedule was ~14 days of twice-daily feedings for ducks (geese, which HVFG didn’t use, historically had longer feeding periods). During each feeding, a worker inserts a metal tube down the duck’s throat and delivers a precise amount of corn-based feed. At Sonoma Foie Gras, for instance, an 8-10 inch steel pipe attached to a pneumatic pump delivered about 10–12 ounces of corn mash in a 4-second burst[30]. Hudson Valley’s process was similar; Michael Ginor described it as a 15-second procedure per duck, often comparing it to “a few seconds of mild discomfort” in the company’s view[37]. By the end of the gavage period, the ducks’ livers enlarge to 6-10 times normal size (reaching ~1 to 1.5 pounds)[38]. Ducks roughly double their body weight in two weeks of force-feeding, becoming extremely obese and lethargic[39]. Housing and Handling: A significant welfare concern is how the ducks are housed during gavage. In Europe during the 1990s, it was common to confine ducks in individual small cages or tightly packed pens. U.S. producers have long claimed their methods were more humane in this regard. Hudson Valley Foie Gras initially used group pens (rather than individual cages) – early 2000s descriptions indicate ducks were “confined eight to a pen, in a huge shed” at Sonoma, and HVFG’s setup was analogous[40]. Each pen is a small enclosure, often elevated with wire or grated flooring to let droppings fall through[41][23]. Ducks can move a bit within the pen, but space is limited; in one account, “eight ducks to an elevated pen” meant they could jostle but not roam freely[40]. The barns are kept dimly lit (to keep birds calm) and temperature-controlled. There is no access to water for swimming (Moulard ducks are ground-dwelling and not given open water in these systems). During gavage weeks, ducks are essentially living by the feeders. Workers approach each pen, grab each duck (often by the neck or wings), and insert the feeding tube. Reports from this era noted ducks often exhibited avoidance behaviors – for example, “huddling away from the force feeder” when the person approached[42]. At HVFG, undercover footage showed ducks trying to back away in their pens, but the confined space “always keeps them within arm’s length” of the feeder[42]. Producers countered that ducks become accustomed to the routine and line up to be fed, though neutral observations did not confirm ducks volunteering happily. Injuries from handling were documented: ducks sometimes had sore or injured bills and throats from the pipe, and panting (a sign of distress and difficulty breathing due to enlarged liver pressing on lungs) was commonly observed in late-stage force-fed ducks[43][44]. Slaughter Practices: Once the gavage cycle is complete (ducks around 12–16 weeks old), the ducks are slaughtered on site. Foie gras farms operate under USDA inspection for slaughter (though notably, poultry are not covered by the Humane Slaughter Act, so there is no legal requirement to stun ducks before killing). Typically, ducks were hung upside down and their throats slit to bleed out, similar to standard poultry processing. Reports from Sonoma’s farm mentioned an on-site incinerator for dead ducks, where each morning carcasses of any ducks that died during the night were burned (with “white smoke… billowing” from it)[45]. Ducks that became too sick or debilitated before scheduled slaughter might be killed by cervical dislocation (neck-breaking) by workers – one manager admitted that “weak or injured ducks have their necks broken” as a culling method[39]. The USDA inspects livers and carcasses for wholesomeness; HVFG often touted that every liver was USDA-inspected and that unhealthy birds were removed from production (often, the mortality rate in gavage is around 2–5%). Michael Ginor claimed the pre-slaughter mortality at HVFG was about 3–4%, which he argued was “lower than in turkey or other poultry industries” (implying that their ducks were not dying at abnormal rates)[46]. “Humane” Branding and Claims: Throughout this period, the foie gras farms attempted to counter animal welfare criticisms by emphasizing their care protocols. They frequently pointed out that ducks are not forced-fed until the final phase – prior to the last 2-3 weeks, the ducks live in barns or outdoor yards where they can eat freely and move in flocks. HVFG and La Belle both highlighted that they do not use “battery cages” like some French producers did. By the early 2000s, HVFG started using the term “cage-free barns” to describe its housing[22]. The ducks were indeed kept in group pens, though critics argue these pens are themselves restrictive. Producers also invoked natural history: they noted that wild waterfowl naturally gorge on food before migration, storing fat in their liver. The gavage process, they claimed, “mimics the natural gorging” instinct of ducks[47][48]. Sam Singer, a spokesperson for Sonoma Foie Gras, in 2003 defended force-feeding by saying it “mimics the natural behavior and no harm is coming to the ducks,” pointing out that state agriculture inspectors had given their farm a “clean bill of health” and found “healthy ducks”[49][48]. Similarly, HVFG’s public materials in the early 2000s described their process as careful and not cruel: they even branded their product as “The Humane Choice” in some promotions[50]. (This claim backfired later; in 2012, HVFG was sued for false advertising over calling their force-feeding humane, and they eventually dropped that language[51][52].) Comparison to European Producers: The U.S. farms often contrasted themselves with old European foie gras farms in an attempt to appear more humane or modern. In Europe, until 2011, it was common to confine ducks individually in small wire cages during gavage. HVFG and Sonoma from the start used group pen systems, which the industry argued were better for duck welfare (allowing some movement and socialization). Ariane Daguin of D’Artagnan once noted that Hudson Valley’s production was “much more humane than in France, as the animals are not caged.” The American producers also did not use geese (which in Europe were sometimes kept in smaller numbers but force-fed more intensely – though by the 1990s even France had mostly shifted to ducks). The feed in the U.S. was a corn mash, similar to France, and delivered by tube – again similar, except some French farms used pneumatic pumps more frequently. By the late ’90s, French foie gras had an image of artisanal farmhouses in the Southwest, though much was industrial; meanwhile HVFG invited media to visit and see what they described as a clean operation. (HVFG in fact maintained an open-door policy by the mid-2000s: “We celebrate interest in meeting the farmers… Please call us to arrange a visit. Media are welcome and pictures are permitted,” their website proclaimed[53] – a clear PR strategy to differentiate from the secrecy of some factory farms.) Despite these claims, investigations revealed numerous welfare issues. Ducks at both HVFG and Sonoma were seen with injuries, infections, and difficulty moving. In one New York Times piece, a reporter visiting Sonoma saw “ducks… so fat they moved little and panted,” with some birds having “untreated sores” and lying dying in pens[50]. Activists documented ducks “covered in vomit”, unable to stand, and one video showed ducks frantically flapping when the feeder approached – evidence of distress[54][55]. The industry responded that these instances were either anomalies or misrepresentations. Mortality and culling were another contested area: Sonoma’s manager admitted some ducks die from heart failure or choking on regurgitated feed during gavage[45]. A 3–4% mortality means thousands of ducks at HVFG died before slaughter each year from complications of force-feeding – something animal welfare advocates highlighted as inherently cruel, while producers compared it to normal farm losses. Changes in Practices (1990s vs. 2000s): Within our period (up to 2004), there weren’t radical changes in husbandry – the basic model (group pens, twice-daily tube-feeding) remained. However, it’s worth noting that outside pressure began pushing for changes. By 2004, California’s impending ban (which provided an 8-year phase-out) had language suggesting producers should research humane alternatives. This led Sonoma Foie Gras’s owner to consider experiments like reduced feeding or gentler methods (though ultimately none satisfied the definition of humane). HVFG and La Belle, after 2004, did start to subtly improve conditions (for example, after 2005, HVFG reportedly expanded pen sizes and phased out any small individual cage use entirely, to preempt regulatory crackdowns). By the early 2010s, both NY farms advertised that they had completely cage-free group housing and had veterinarians regularly monitoring duck health – but these improvements were largely a response to the activism and legal scrutiny that ramped up in the early 2000s. In the 1990s, such welfare concerns were not widely publicized; it was only in the 2000s that the “humane vs. inhumane” debate forced the farms to articulate and adjust their internal standards. In summary, from 1990s to 2004, HVFG and La Belle adhered to industry-standard foie gras practices – intensive force-feeding in confined spaces – while publicly insisting they did so “humanely.” They took pride in some differences from old European methods (no individual cages), yet the “extreme” nature of gavage remained at the heart of welfare critiques[29][56]. Both farms stood by the claim that if done correctly, force-feeding does not cause undue suffering, citing healthy-looking ducks and normal behavior (a claim strongly disputed by animal welfare experts and undercover evidence).

One striking aspect of foie gras’s pre-1980 history in the U.S. is the near-total silence about how it’s made. In France, foie gras production involves the controversial practice of gavage – force-feeding ducks or geese to enlarge their livers. But American cookbooks, media, and importers of the time scarcely mentioned this aspect. The prevailing approach was either to euphemize or omit details of production, keeping the focus on the end product’s luxury. Presentation of Production in Literature: When foie gras was referenced in cookbooks or food literature, the language was usually genteel. For example: A 1960s American encyclopedia of food might define foie gras as “the fat liver of specially fed geese, a great delicacy of French cuisine.” Note the phrasing “specially fed” – a polite way to imply force-feeding without saying it. This phrasing mirrors the French legal definition (which the USDA adopted) that foie gras comes from “specially fed and fattened” fowl[5]. The ugly mechanics of a metal tube down a goose’s throat were not described. Larousse Gastronomique (the French culinary bible, available in English by 1961) did mention how geese are fattened on maize and water, etc., but it treats it as a matter-of-fact traditional technique, not dwelling on potential cruelty. An average American reader of Larousse would gloss over it as just another Old World farm method, akin to any animal husbandry. Julia Child’s Mastering the Art of French Cooking (1961) doesn’t include foie gras recipes – because one simply couldn’t get raw foie gras here – but it does have pâté recipes. In those, she sometimes calls for “good quality goose liver pâté (foie gras) if available.” She doesn’t delve into how that foie gras is obtained. Julia, ever the pragmatist, likely thought such discussion unnecessary or potentially off-putting to her audience. An illustrative example of euphemism can be found in importer/distributor materials. Gourmet shops selling imported foie gras in jars might advertise it as “from geese raised on the corn-rich farms of Alsace” or “the product of traditional feeding methods that produce a succulent liver.” Again, phrased positively – traditional, corn-rich diet – which sounds almost bucolic. The reality of a gavage funnel is left unsaid. Concealment vs. Openness: Essentially, production was concealed in plain sight. It’s not that nobody knew – indeed any chef who’d been to France or any serious gastronome probably was aware that geese were force-fed (this had been known for centuries). But it was considered a non-issue or even a positive (to achieve the delicacy). The attitude was “don’t spoil the appetite by talking about farm grit”. This is similar to how veal was discussed at the time: people knew veal came from young calves, but details of tethering/crating were not public discourse then. In the U.S. context, since foie gras was all imported, there was no investigative journalism into domestic farms (as there would be decades later). And since it was small-scale, it escaped the notice of activists concerned with slaughterhouses or big agribusiness. No animal welfare organization in the U.S. made foie gras a topic before the 1980s. One could scour the archives of groups like HSUS or PETA (founded 1980) and find virtually nothing on foie gras in their early literature. (Interestingly, the Humane Society archives index lists files on “pâté de foie gras 1974-1985”[17], suggesting they only started compiling info by the mid-’80s, likely in response to new concerns or import issues then.) Early Criticisms (International): If there were any early murmurs, they were more likely in Europe. For instance, in Britain, some letters to the editor in the 1970s might have decried gavage as cruel. In 1975, the Council of Europe actually considered standards for animal welfare that touched on force-feeding, but this was low-profile. The U.S. public by and large didn’t hear about it. It wasn’t until 1981 that the first modern campaign against foie gras (by the UK organization CIWF) made headlines in the UK, and that still didn’t immediately reach the U.S. Language Used in Pre-1980 Sources: A few examples highlight how carefully language danced around the issue: A 1959 New York Times piece on French food imports described “the famous pâté de foie gras, made from the enlarged livers of geese”. Enlarged is a neutral term – true but not explicitly stating how. No mention of force-feeding; it sounds like a naturally large liver. A 1970s gourmet food catalog might say: “Our foie gras pâté comes from the Dordogne region, where geese are nurtured to produce livers of exceptional richness.” “Nurtured to produce” is a rosy spin on forced gorging. These sorts of descriptions kept the consumer comfortably ignorant. And consumers, for their part, may have preferred not to inquire too closely. It’s akin to how in that era, few people asked about how their foie gras (or veal or foie gras or fur) came to be; they focused on enjoying the end product. Absence of Scrutiny: To underscore: there was no visible scrutiny or critique of foie gras production in American mainstream discourse pre-1980. No newspaper exposés, no television documentaries, nothing. The first wave of scrutiny would come in the late 1980s after the first U.S. foie gras farms opened, when activists could physically go film the force-feeding. Before that, it was out-of-sight, out-of-mind, taking place an ocean away on small French farms or Hungarian collectives. It’s worth noting that even French food writers of the mid-20th century were often taciturn about gavage. It was treated as a normal rural practice – maybe a bit messy or coarse, but necessary to achieve something sublime. That was the mentality passed on to American epicures. Thus, early American adopters of foie gras weren’t hiding from an uncomfortable truth so much as they didn’t consider it problematic. If anything, they might boast that foie gras was so valued that special feeding techniques were developed – spinning it as a testament to human ingenuity in gastronomy, rather than cruelty. Conclusion of this Aspect: The pre-1980 era can be characterized by a romantic veil over foie gras: consumers saw the luxury and tradition, not the funnel and pen. Any “production narrative” given to the public was sanitized. It was common to reference that foie gras came from geese that “gorge themselves seasonally in nature” (true, wild geese do fatten for migration) and imply gavage was just mimicking nature. For example, a 1970s French cooking column might cheerfully explain: “The goose naturally stores fat in its liver for winter; on the farm, we simply help it along by ample feeding – that’s how foie gras is obtained.” This half-truth kept the practice shielded from critique. In the broader social context, concern for farm animal welfare was only beginning to emerge (the first U.S. laws on humane farm treatment wouldn’t come until much later). So foie gras’s production flew under the radar until later epochs. As we move past 1980 in history (beyond the scope of this question), that would change dramatically – but prior to that, foie gras enjoyed a controversy-free existence in the American market.

Facing constant criticism, the U.S. foie gras producers have in recent years emphasized alleged improvements in their farming practices – seeking to rebrand their product as more humane or “artisan.” It’s a clear bid to counter the cruelty narrative. Here’s a look at what the industry claims in terms of duck welfare, and how those claims stack up: “Cage-Free” Foie Gras: Both Hudson Valley Foie Gras and La Belle Farm now stress that their ducks are no longer kept in the old-style individual confinement cages during force-feeding. Hudson Valley proudly advertises its operation as cage-free[73]. On its website, HVFG notes that “most foie gras farms in the world” historically used individual cages for efficiency, but says “we believe in providing conditions which allow for social interaction, exercise, freedom of movement, and reduction of stress. For this reason, our ducks are maintained cage free.”[73]. Indeed, some years ago HVFG transitioned to group pens where ducks can move around and interact (the old metal isolation cages were phased out around the late 2000s under pressure). This is a notable welfare improvement on paper – it allows ducks to walk and flap their wings in between feedings, rather than being immobilized. However, it does not eliminate force-feeding or the stresses of intense confinement in a barn. Critics also point out that the group pens, while better than tiny cages, still crowd dozens of ducks together on wire mesh flooring, which can cause foot injuries and prevent natural behaviors like swimming[74][75]. So, “cage-free” in this context means ducks are penned, but not individually tethered. “Hand-Feeding” Techniques: The farms have sought to euphemize gavage as “hand-feeding” and claim it is done gently. HVFG says it employs “specially trained caretakers” who spend extra time with each bird – “four times as much time caring for each animal as is the case in other foie gras farms,” resulting in “special care” for the ducks[76]. They also highlight that they use a rubber or plastic tube (instead of a rigid metal pipe) to minimize injury, and that feed is administered by hand rather than entirely mechanical means. (That said, videos show La Belle at least uses pneumatic pumps to speed the process[77].) Both farms assert that their “unique, special method” of feeding “does not harm the ducks”[78][79]. In a 2022 press statement, the farms stated: “Both farms produce foie gras using a special hand-feeding method, like no other farm in the world, so as not to harm the ducks.”[78] This suggests they believe their approach is more humane than foie gras farms elsewhere (perhaps because they no longer use individual gavage crates, whereas some foreign farms only banned those in recent years). Farm Conditions & Care: The producers often invite chefs, reporters, and even lawmakers to tour their facilities (a tactic to demystify and normalize their practices). La Belle’s president Sergio Saravia has said “our ducks are well cared for, are allowed to roam freely,” and processed under USDA inspection[80]. He has challenged detractors to visit in person and “see, firsthand, the farming practices we have in place.”[81] Similarly, Marcus Henley of HVFG insists “everything we do is with the ducks’ welfare in mind.”[82] On tours, they show ducks in open pens, clean waterers, and claim the animals exhibit normal behavior (they often point out the ducks don’t run away from feeders – implying they aren’t terrified, though skeptics note the ducks are essentially conditioned and have reduced flight response). The farms tout on-site veterinarians and adherence to regulations. Notably, HVFG once tried to brand itself “The Humane Choice” in marketing materials[83]. This prompted ALDF to sue for false advertising in 2012–2013; HVFG eventually removed that slogan to settle the case[84][85], but the fact they used it indicates how strongly they wish to portray their foie gras as ethical. Scientific Rationalizations: The industry frequently cites waterfowl physiology to argue that gavage isn’t cruel. For example, HVFG’s website, quoting a sympathetic veterinarian, notes that ducks have hardened throats (esophagi) with tissue like the palm of a hand (so they can swallow fish and supposedly tolerate a tube)[86]. It points out ducks lack a gag reflex since their trachea opens in the tongue, not the throat, so they can breathe during feeding[87]. And it mentions that waterfowl naturally store fat in their liver for migration, and that this fattening is a “reversible process” in birds (implying foie gras is just an extreme extension of a natural ability)[88]. These talking points have been used for years to counter the cruelty claims. While it’s true ducks can eat large meals and have some unique anatomy, independent veterinarians (including the European Union’s scientific committee) have refuted the idea that force-feeding to the point of organ pathology is benign – concluding that it “is detrimental to the welfare of the birds” and that the enlarged liver is severely compromised and diseased[89][90]. No Force-Feeding Alternatives: One thing notably absent from U.S. industry reforms is any move toward producing foie gras without force-feeding (so-called “naturally fatty liver” from non-gavaged birds). In Spain, a farm (Eduardo Sousa’s) gained fame for making foie gras by timing the ducks’ natural gorging season (no gavage), but it yields very limited quantities. U.S. producers have not attempted this; they maintain that controlled gavage is necessary for commercial viability. So, all talk of welfare reforms is within the context of continued force-feeding. Third-Party Audits or Certifications: Unlike some sectors, foie gras farms in the U.S. are not certified by animal welfare programs (e.g. Global Animal Partnership, etc. – those programs inherently wouldn’t allow force-feeding). The farms do point to their USDA inspection for food safety and state agriculture oversight, but that doesn’t equal animal welfare certification. There are no independent animal welfare audits made public. In a twist, La Belle Farm’s owners have diversified into humane-certified poultry farming: they launched LaBelle Patrimoine, a separate venture raising pasture-raised heritage chickens with high welfare standards (earning a Good Chicken Award from Compassion in World Farming in 2024)[91][92]. However, this applies to their chicken line, not their duck foie gras operation. One might cynically note that the same family that force-feeds ducks is also producing GAP Step-4 rated chickens – indicating that they recognize the market for truly humane products, even as they continue foie gras on the side. Contradictions and Verifications: Animal rights groups vigorously dispute the farms’ rosy portrayals. Video evidence (past and recent) appears to contradict claims that foie ducks “roam freely” or are not harmed. For example, HVFG’s statement that ducks have freedom of movement is belied by footage of ducks in confined pens on wire floors, unable to swim or fly and piling on each other when frightened[93][77]. The claim that the ducks willingly accept feeding is refuted by scenes of ducks recoiling or trying to flee the feeder in undercover clips[94][95]. No independent welfare expert has endorsed the U.S. foie gras farms as humane. In fact, veterinary and animal behavior experts (outside those hired by the farms) overwhelmingly side with the view that force-feeding is cruel. The farms’ open-door policy for media has sometimes backfired: journalists who visit often note the apparent distress of the animals. For instance, a reporter touring La Belle in 2019 described ducks huddling and vocalizing in discomfort as the feeding tube was inserted, and characterized the process as assembly-line force-feeding[57]. Such first-hand accounts, even if not as brutal as the worst undercover videos, still convey suffering. In summary, the industry’s “humane foie gras” narrative is a mix of minor improvements and marketing spin. True, ducks at HVFG and La Belle are no longer isolated in tiny cages – a practice that even many European producers have abandoned – and the use of plastic tubes and more attentive feeding might reduce the incidence of certain injuries. But the core practice remains the same: over two weeks, ducks are forcibly overfed to the point of organ failure. Producers argue they’ve made foie gras “as humane as it can be,” but animal advocates respond that foie gras by nature can never be humane. Notably, when Hudson Valley once tried calling its product “the humane choice,” it was forced to cease that claim after legal challenge[96][85]. The farms now stick to more subtle language like “ethical practices” and emphasize ancillary things like being family-run or having decades of experience. Ultimately, the industry’s attempt to rebrand as artisan farming – with cage-free barns and “hand-fed happy ducks” – has convinced very few outside the fine-dining world. And without independent welfare audits, these claims remain self-attested. As the ALDF bluntly put it, Hudson Valley “brutaliz[es] ducks for gourmet profits” even as it tries to present a caring image[97].

The process of making foie gras is inherently tied to animal welfare questions, even if those questions weren’t front-and-center in the 1980s. Early U.S. producers developed husbandry and feeding practices based on European methods, and each had their own narrative to justify or frame what they were doing. Here we examine how the ducks were raised and how farmers described their methods in the early years: Husbandry and Gavage Practices: Species and Breeds: Notably, all U.S. foie gras in the 1980s came from ducks, not geese. While traditional foie gras in Europe included goose liver, the American pioneers opted for ducks from the start – largely due to advances in duck breeding. The predominant choice was the Moulard (mule) duck, a hybrid between a male Muscovy and a female Pekin duck. This hybrid is sterile (it “must be artificially inseminated to produce ducklings”), but it has traits ideal for foie gras: a voracious appetite, large size, and hardiness. The Moulard’s liver also has a slightly different taste and texture that many producers and chefs came to prefer. Sonoma Foie Gras was an exception in breed – Guillermo Gonzalez started with a pure Muscovy duck strain (a large duck as well)[4]. Muscovies can breed naturally, which simplifies flock reproduction, but they still yield rich fatty livers. In either case, geese were not used in the U.S. early on. (This may have been due to geese requiring longer feeding periods and being less economical; by the ’80s even French producers were shifting heavily to ducks for similar reasons.) Feeding Regimen Duration: American farms followed the same general timeline as in France: ducks would be raised normally for a period, then force-fed for several weeks to engorge the liver. At Commonwealth/HVFG, ducklings were reared on regular feed for about 8 weeks, then moved into the gavage phase for about 3–4 weeks. During gavage, they were typically fed “several times a day” – commonly twice a day for ducks in the traditional method, or sometimes three times in accelerated programs. The feed was usually a mix of boiled corn (maize) and fat, sometimes with additives. Early on, Howard Josephs described his approach as “manually fed several times a day for 3–4 weeks”, which is essentially the textbook foie gras process. In Ohio, Guy Michiels claimed he could do a shorter 18-day feeding period by using salted water to induce thirst and appetite, though it’s unclear if that was ever proven. Sonoma Foie Gras stuck with a longer, gentler cycle: Guillermo Gonzalez mentioned 24–25 days of force-feeding by the traditional method. In contrast, he noted French industrial farms had shortened it to 12–14 days by the 1990s with more intensive force-feeding. So U.S. producers in the ’80s generally followed the older, ~3-week model. Housing and Confinement: The conditions in which ducks were kept during gavage evolved over time, but early descriptions give a sense: “then put in cages, several ducks to a cage” is how the Catskills farm setup was described in 1983. This suggests that group penning was used – small cages or pens holding perhaps 4–6 ducks together. They would be confined enough to restrict movement (so energy isn’t wasted and to make feeding easier) but not yet the individual cages that later became common in some foie gras facilities. Josephs also mentioned raising ducks year-round in a controlled atmosphere as opposed to seasonally. So barns were likely climate-controlled, a departure from the small outdoor gavage huts of traditional small French farms. By the late ’90s, some U.S. practices did shift toward individual cages, but importantly Sonoma Foie Gras explicitly did not use individual cages. Gonzalez described their setup as “four square meters for 10 ducks” during feeding, where a feeder enters the pen and grabs each duck in turn. This is a floor-pen method, which is arguably better for welfare than tiny cages. It’s actually the old French small-farm method, and Sonoma stuck to it as a selling point. At Hudson Valley, exact practices in the ’80s are less documented (they were quite secretive at first), but later investigations in the ’90s found many ducks in larger shed pens before feeding, then small pen enclosures during gavage. By the 2000s, HVFG had moved toward a pen system (no individual cages) with about a dozen ducks in a pen of 4ft x 6ft, which is similar to Sonoma’s density. So overall, early U.S. farms tended to use group pens for feeding, not individual “crates,” at least in the 1980s. The housing was restrictive but not the worst possible, and producers often claimed the ducks could still move a bit, stand, and lie down normally (which they cited as a humane practice). Mortality and Health Issues: By design, foie gras induction is hard on the animals – that’s an unspoken reality. However, in the 1980s, producers did not publicize any data on duck mortality or health problems. They likely experienced losses (ducks that died during the feeding period from complications). Modern figures, uncovered later, indicate that mortality rates in foie gras ducks can be 5% or higher during gavage – up to 20 times the normal duck mortality rate on a farm. But early on, the narrative from farmers was that their ducks were healthy and thriving. Howard Josephs went as far as to say his ducks were “remarkably hearty and healthy – and affectionate”, even following humans around like pets. He obviously downplayed any negatives. It’s reasonable to assume early farms had to learn by trial; for instance, overfeeding too aggressively can cause ruptured organs. Pioneers like Izzy Yanay, with prior experience, probably managed the feeding to minimize deaths, but when PETA later investigated (in 1991), they found that at Commonwealth/HVFG a single worker had to feed so many ducks that many birds were mishandled and “so many ducks died from overfeeding that workers who killed fewer than 50 birds per month were given a bonus”. If true, that chilling detail suggests that even in the early years a substantial number of ducks were dying from the process – something the farm would never have advertised. Instead, public-facing statements highlighted if anything low mortality. Izzy Yanay and Michael Ginor later claimed their animal loss rates were low and comparable to other poultry farms, but independent data was lacking in the ’80s. Self-Narratives and Ethical Justifications by Producers: “No Force-Feeding Here” – Reframing the Practice: A striking aspect of early producer narratives is the attempt to linguistically recast what they were doing. Howard Josephs insisted he did not “force-feed” at all. He told reporters that his special high-protein corn mix made the ducks “want to overeat” naturally. This is a bit of a PR sleight-of-hand; while it’s true ducks will fill their crop if very tasty food is available, it’s not true that they’d engorge their liver 10x without coercion. Nonetheless, Josephs maintained that “the birds are fed a high-protein formula… that makes them want to overeat.” In other words, he portrayed gavage as voluntary feasting by the duck. This claim was viewed skeptically by journalists even then, but it was part of his ethical defense. By denying “force”, he tried to preempt the cruelty argument. Similarly, he flat-out refused to let reporters visit the feeding area of his farm, citing “trade secrets”. The secrecy indicated he knew the optics were bad, regardless of terminology. Emphasizing Tradition and Natural Behavior: Producers often leaned on the idea that foie gras mimics a natural process. They would remind people that wild ducks and geese naturally gorge on food in preparation for migration, storing fat in the liver. The farmers just helped them do this. Izzy Yanay, for example, later described that ducks have no gag reflex and can ingest whole fish, implying that tube-feeding them corn wasn’t painful or unnatural. This wasn’t heavily documented in the ’80s press, but it was certainly part of the internal narrative. Guillermo Gonzalez took a slightly different tack: he highlighted that their method was the old, slow method – implying it was more “natural” and “humane”. In a 2001 interview, while diplomatically acknowledging the issue (“It depends on what your philosophies are about that” he said of force-feeding), he explained that Sonoma’s feeders personally handle each duck, in small groups, gradually increasing feed. By contrasting this with “factory farming” (individual cage, machine pump) which he said France was doing, he cast Sonoma’s approach as more humane and traditional. This served as both an ethical justification (we do it the kinder way) and a quality brag (our foie gras tastes better because the ducks aren’t stressed by machines). Claims of Humane Treatment: Across the board, early foie gras producers claimed they cared for their animals well. They pointed out the ducks were given good living conditions (within the context of foie gras). For example, “controlled atmosphere year-round” farming meant ducks weren’t subject to extreme cold, etc., which the farmers would say keeps them comfortable. When animal welfare lawyers in 1983 raised concerns about stress and injuries (like esophagus damage or difficulty standing for ducks with huge livers), producers countered that their ducks did not suffer such issues in any significant way. Josephs got angry at the suggestion of wrongdoing, implying he felt persecuted: “Fifty percent of people in the U.S. think we are smugglers,” he complained, adding that he had to fight that misconception. This suggests he lumped welfare critics in with people questioning the legitimacy of his operation. Izzy Yanay, who had decades of foie gras experience, was known to invite skeptics (years later) to “visit the farm” and see for themselves. The subtext even in the ’80s was: if you see our farm, you’ll see healthy ducks, not abused creatures. By offering transparency (at least later on, if not in the very first years), producers tried to demonstrate confidence that their methods were ethical. Humaneness vs. Europe Narrative: Early U.S. producers sometimes implicitly (or explicitly) suggested they were doing a more humane job than some European producers. For instance, Guillermo Gonzalez noted French chefs were complaining about foie gras quality because of the new intensive methods in Europe – “It is not the same flavor… not the same texture… from the more traditional method.” This comment not only sells his product’s quality but insinuates that the new European factory farms (with individual cages, pneumatic force-feeders) were cutting corners in a way that hurt both ducks and the product. By positioning American foie gras as artisanally made, producers gave it a moral edge in the narrative: it’s “the right way” to do foie gras. Decades later, the concept of “humane foie gras” (with cage-free feeding, etc.) would be hotly debated, but in the 1980s the American foie gras = more humane idea was just beginning to form. In part, this was because U.S. farms were small and hands-on. There’s a telling note: in Israel (where Yanay had run farms), the industry in the ’80s had tens of thousands of geese being force-fed – a larger, more industrial scale. The U.S. startups, in contrast, had the luxury of being relatively small-scale and could claim more individualized care. Evasiveness and Secrecy: Not all narratives were kumbaya – producers could be evasive. As mentioned, Commonwealth’s owner refused farm visits and clammed up about details like exact feeding methods, calling them trade secrets. This indicates a defensive stance; he likely feared bad press if images of ducks being tube-fed hit the mainstream. In another instance, a Newsweek reporter who did visit a foie gras farm in that era described the ducks as “listless” and “often lame from foot infection” in cages. That was exactly the kind of description producers wanted to avoid in the press. Hence, their narrative emphasized only the positive (healthy, happy ducks) and framed any downsides as either minor or outright denied. In essence, early foie gras producers in the U.S. walked a fine line: they were bringing forth an inherently controversial practice, but they introduced it in a low-key manner with preemptive justifications. They stressed tradition, compared themselves favorably to industrial farming, and portrayed their ducks as living good lives (until the end). These self-narratives were crucial in the ’80s, because they faced so little direct activist challenge – the farmers essentially got to shape the story largely on their own terms during this early period.

Worker force-feeding ducks on a foie gras farm (Hudson Valley Foie Gras in New York). Producers contend that when done with modern techniques and care, the force-feeding (“gavage”) process is humane, though animal advocates strongly dispute this.[118] One of the more intriguing aspects of the California foie gras saga is how producers responded to the animal welfare criticism at the heart of the ban. Facing accusations of cruelty, foie gras farmers undertook public and private efforts to defend or improve their practices. Here’s a look at what producers did (or claimed to do) regarding animal welfare from 2012–2019: Public Denials of Cruelty: From the moment the ban was proposed (and ever since), producers have insisted that their methods do not constitute cruelty. Guillermo González of Sonoma Foie Gras maintained that his farm had the “utmost respect to animal husbandry practices” and that his “conscience is clear” about producing foie gras[122][123]. Marcus Henley of Hudson Valley frequently stated that the ducks are healthy and calm during the process, often emphasizing that the farm doesn’t use the tiny individual cages seen in some European facilities. In court, the industry even tried to present expert testimony that force-feeding, if done correctly, does not harm ducks the way activists claim (though the battle was mainly fought on legal grounds, not factual animal welfare claims). “Humane Foie Gras” Initiatives: Feeling the heat from activists, producers in the late 2000s and early 2010s made tangible changes to farming practices. Both Hudson Valley Foie Gras and La Belle Farm (the two NY producers) phased out the use of individual confinement cages (which restrain a duck completely) and shifted to group pens where ducks can move a bit within a small enclosure. They also shortened the force-feeding period (to about 10–12 days at Hudson Valley) and maintained that they followed guidelines to ensure birds didn’t suffer injuries. These changes were partly in response to European regulations – the EU, for example, banned the use of individual cages in foie gras production after 2010 – and partly to counter the graphic imagery used by activists. By the time California’s ban took effect, U.S. producers were keen to show they were different from the worst actors (like some French farms or a defunct Israeli farm that had extremely harsh conditions). They invited humane certification organizations and veterinarians to observe. Ken Frank, in his pro-foie 2012 op-ed, highlighted that “working closely with some of the best independent animal welfare experts, [foie gras farmers] have developed rigorous, comprehensive humane protocols” covering every stage of production[124][125]. These protocols included things like gentle handling techniques, using plastic (softer) tubes instead of metal pipes for feeding, monitoring each bird’s health daily, and ensuring ducks had periods of rest. Frank asserted that due to these improvements, “there simply is no longer an objective case to be made” that foie gras production is torture[77][116]. Transparency and Farm Tours: A major component of the producers’ response was to open their doors to media and outsiders – a stark contrast to many factory farming operations. Hudson Valley Foie Gras, in particular, allowed multiple journalists, culinary professionals, and even some skeptics to tour their farm. The most cited example is the Village Voice story from 2009 titled “Is Foie Gras Torture?” in which reporter Sarah DiGregorio visited Hudson Valley with guidance from both activists and the farm[118]. She was shown every part of the process. According to Ken Frank’s summary, the reporter expected to find extremely sick, dying ducks (as per activist warnings) but instead found relatively normal-looking ducks and concluded that foie gras could be produced humanely (noting one can buy humane vs. inhumane chicken, and “the same goes for foie gras”)[118][126]. The producers widely circulated this article as vindication – essentially using it to say, “look, an objective journalist saw our farm and wasn’t horrified.” Similarly, Guillermo González often invited chefs and reporters to Sonoma Foie Gras (prior to its closure) to show that his ducks were kept in open barns and that the feeding was done by hand with care. Producers also voluntarily underwent audits: for instance, Humane Farm Animal Care (which runs the “Certified Humane” label) was reportedly approached to develop foie gras standards. While Certified Humane ultimately decided not to certify foie gras, the dialogue itself signaled producers’ willingness to engage with welfare standards. Handling Critiques and Making Adjustments: Producers did implement certain welfare tweaks in response to specific critiques: Activists pointed out that ducks often suffered throat injuries from the feeding pipe. Producers responded by using softer, flexible feeding tubes and training workers to insert them gently and at proper angles. There were concerns about ducks being terrified and struggling. At Hudson Valley, workers began carrying ducks under one arm in a calm manner and sometimes played classical music in the gavage room to keep a soothing atmosphere (this has been reported anecdotally by farm visitors). The ban law itself gave them 7+ years to find alternatives. While no alternative to gavage was found, there was exploration: researchers looked at whether certain breeds of duck might naturally overeat, or if diet formulas could induce fatty liver without force. None of these panned out commercially, but the producers did engage with some science (for example, testing feeding frequency or feed composition to minimize stress). It’s worth noting that one California-specific alternative was attempted: a businessman named John Dodman in the late 2000s proposed something called “Sonoma Artisan Foie Gras” – a process to make foie gras by breeding ducks that would overeat voluntarily if given free-choice high-fat food. It didn’t achieve the desired result (ducks won’t gorge to the same extreme as gavage induces, absent migratory instincts). So, by 2012, that effort had fizzled. This shows that while producers and entrepreneurs did explore humane methods, none rivaled the efficiency of gavage. Alternative Products and Rebranding: Facing the ban, some in the industry considered diversifying. For example, Guillermo González after closing Sonoma Foie Gras pivoted to selling other duck products (like duck meat, magret, etc.) which were not banned. Hudson Valley and others emphasized that they raise ducks for more than just liver – the ducks’ meat and down are also products. So one could argue they were multi-use farms, not solely force-feeding for liver. This didn’t change the ban but was a PR angle (“we use the whole animal,” etc.). In terms of rebranding: The term “foie gras” itself became somewhat tainted in California. One restaurant in 2012 cheekily put “midnight mousse” on the menu as a code for foie gras. But more substantially, companies like Regal Vegan in NYC launched a product called “Faux Gras,” a vegan pate made from nuts and mushrooms, trying to capitalize on the foie gras controversy by offering an ethical alternative. While not a producer response per se, it shows how the market responded to consumer conscience – and foie gras producers took note of this niche competition, often deriding such products but also highlighting that real foie gras was a cultural irreplaceable item. They argued that rather than substitutes, the answer was to make real foie gras more ethically. Industry Self-Regulation vs. Law: The producers’ narrative of improved welfare was essentially an argument for self-regulation as an alternative to prohibition. They suggested that rather than an outright ban, California could have set humane foie gras production standards. In fact, during the legislative debates in 2004, that idea was floated – but no concrete alternative method was known, so the law defaulted to an eventual ban. By 2017, when Chef Ken Frank proposed “let’s craft the world’s highest humane standards and repeal the ban”[77][78], it was likely too late politically (and moot since there were no producers left in CA to regulate). However, the discussion did influence producers elsewhere: the concept of “humane foie gras” started to gain currency. In Spain, a farm owned by Eduardo Sousa produces “natural foie gras” without force-feeding (letting geese gorge seasonally). This was held up as proof that foie gras could be made ethically. Acclaimed chef Dan Barber even featured Sousa’s foie gras at his restaurant and in a TED Talk. U.S. producers acknowledged Sousa’s method but argued it’s not replicable on a large scale (Sousa’s output is tiny and inconsistent). Nonetheless, the very term “humane foie gras” forced producers into a defensive stance – they had to convince people that their foie gras was humane too, even if produced by gavage. Ongoing Disputes Over Reality: Despite producers’ assertions, animal advocates continued to document problems at foie gras farms. During the California ban years, at least one undercover video (circa 2013) from inside Hudson Valley Foie Gras by an activist with Compassion Over Killing showed workers roughly handling ducks and some birds appearing sick or panting (signs of distress). Producers dismissed such footage as isolated or misleading. They pointed to the overall health of their flocks: Hudson Valley would say things like “our ducks are free-range until the last few weeks” (though activists dispute how free that range truly is). They also pointed out that ducks naturally store fat in their livers (a fact activists acknowledge, but not to the extreme induced by force-feeding). The scientific reality is that foie gras production induces hepatic lipidosis (fatty liver disease) in the ducks – producers don’t deny this, they just argue it’s a reversible condition if the duck wasn’t slaughtered, and that during the process the ducks aren’t in pain as long as it’s done properly. Activists and many vets strongly disagree, citing evidence of pain, stress hormone spikes, and pathology. This back-and-forth persisted through 2012–2019. Credibly Reported Changes: To directly address the prompt: Did producers credibly change any on-farm practices? Yes, they eliminated the worst confinement practices (no individual cages by the main U.S. producers by 2012, only group pens – which is an improvement, though group pens still restrict movement). They improved feeding technology (using pneumatic pumps that deliver measured amounts of feed quickly, reducing the time the duck is handled and the tube is in its throat, and using smoother tubes). They increased veterinary supervision – HVFG hired a full-time vet tech to monitor duck health. They also adjusted the ducks’ diet in the pre-force-feeding phase to keep them healthy and not overly stress them when force-feeding begins. These changes are documented in farm audit reports and some producer communications, though not all are independently verified in public records. Whether these constitute “humane” treatment is subjective; animal welfare scientists would likely say they mitigate but do not eliminate suffering. Post-2019 Outlook: After the Supreme Court let California’s ban stand, producers doubled down on fighting the NYC ban and preventing others. They touted their farming as humane to try to dissuade other legislators from considering bans. The long-term industry approach to welfare thus became: show that we can raise ducks nicely and that force-feeding is not the horror it’s made out to be – hoping to preserve at least the status quo (and ideally roll back California’s ban someday). California’s law ironically incentivized producers to improve welfare, in the sense that they were under a microscope and those improvements were their only defense. In essence, California’s action forced foie gras producers to confront the ethics of their practice more directly than ever before. While they did not concede that force-feeding is cruel, they did make changes and attempt to present a narrative of humane reform. They pushed “humane foie gras” narratives aggressively – such as claiming ducks come eagerly to be fed (a contested claim), or that the ducks only experience mild temporary discomfort akin to “overeating at Thanksgiving dinner,” etc. These narratives were part PR, part reflecting actual husbandry tweaks. To an outside observer, the credibility of these claims might be questionable given the fundamental nature of foie gras production, but the producers certainly tried to back them up with transparency and expert support. From a policy perspective, none of these efforts swayed California’s lawmakers or courts (since the ban remained), but it might have influenced public perception in some quarters and possibly prevented legislative bans elsewhere by creating doubt (“maybe it’s not so cruel now”). To summarize, producers responded to California’s ban by attempting to demonstrate that foie gras could be produced more humanely, through concrete changes in farming practices and a concerted public relations effort. While activists maintain that foie gras by force-feeding is inherently inhumane, the industry’s efforts did result in somewhat better conditions on foie gras farms (no small cages, etc.) compared to earlier eras. California’s stance essentially pressured the industry to “clean up” as much as possible – a legacy of the ban that arguably improved the baseline welfare of ducks on foie gras farms outside California, even though it didn’t change the minds of California’s policymakers. Sources: Dolan, Maura. “California’s foie gras ban is upheld by appeals court.” Los Angeles Times, 30 Aug. 2013[127][6]. (Ninth Circuit 2013 decision details) Taylor, Daniel. “Calif.’s Foie Gras Ban Struck Down by Federal Judge.” FindLaw, 8 Jan. 2015[15][17]. (District court 2015 preemption ruling) Stempel, Jonathan, and Lisa Baertlein. “Appeals court revives California ban on foie gras.” Reuters, 15 Sept. 2017[20][23]. (Ninth Circuit 2017 decision and reactions) City News Service. “California foie gras ban goes into effect after Supreme Court rejects challenge.” Los Angeles Times, 7 Jan. 2019[31][33]. (Supreme Court cert denial and enforcement) Shackford, Scott. “California Authorities Prepare to Not Really Bother to Enforce Foie Gras Ban.” Reason, 26 June 2012[60][43]. (Enforcement, workarounds, Sonoma FG closure quote) Gravel2Gavel Blog. “Environmental Case Law Update – March 2015.” Gravel2Gavel, 3 Mar. 2015[13][51]. (Discussion of 2015 ruling, economic impact claim) CBS/AP. “Foie gras from out of state can now be served in California.” CBS News, 15 July 2020[53][34]. (One-third sales loss figure, 2020 court loophole) Pershan, Caleb. “Foie Gras Lawsuit Dismissed Against Napa’s La Toque.” Eater SF, 28 Aug. 2019[67][128]. (Details on ALDF suit, court’s clarification on “gift” = sale) Dolan, Maura et al. “Chefs react angrily as federal appeals court upholds California ban on foie gras.” Los Angeles Times, 15 Sept. 2017[129][107]. (Chefs’ quotes: Chaney, Greenspan, Fraser; HSUS quote) Inc. Magazine (Patrick Sauer). “Entrepreneur Backs Law that Will Close His Doors.” Inc.com, 19 Sep. 2005[47][48]. (Sonoma FG owner supporting 2004 law for immunity) Parsons, Russ (quoting Ken Frank). “In favor of foie gras – Ken Frank speaks out.” LA Times Daily Dish blog, 11 Apr. 2012[124][118]. (Chef Ken Frank on humane foie gras progress and Village Voice story) Poirier, Kira. “Victory for birds: U.S. Supreme Court upholds California foie gras ban.” SPCA Montreal, 2019[93][94]. (Context of global foie gras bans and cruelty description) ALDF. “Animal Legal Defense Fund v. LT Napa Partners (La Toque) case summary.” AnimalLaw.info, 2015[62][58]. (Investigator findings at La Toque) Farm Sanctuary Blog. “The Truth about Foie Gras: Part 1 (Interview with Bruce Friedrich).” Farm Sanctuary, 29 Jan. 2014[89][91]. (Activist perspective on challenges and legal actions, mentions suing USDA under PPIA and effectiveness of ban) Hernández-López, Ernesto. “California Bans on Pork, Foie Gras, Shark Fins, and Eggs” SSRN paper, 2014[109][110]. (Scholarly discussion of California’s animal welfare laws and constitutional issues) [1] [2] [3] [25] [30] [56] [80] [81] California foie gras law - Wikipedia https://en.wikipedia.org/wiki/California_foie_gras_law [4] [82] [83] [95] [96] Victory! California’s Foie Gras Ban Upheld by the Supreme Court https://www.idausa.org/campaign/farmed-animal/latest-news/victory-californias-foie-gras-ban-upheld-by-the-supreme-court/ [5] [6] [7] [8] [9] [10] [11] [12] [41] [127] California's foie gras ban is upheld by appeals court - Los Angeles Times https://www.latimes.com/business/la-xpm-2013-aug-30-la-fi-foie-gras-20130831-story.html [13] [14] [16] [37] [38] [51] [52] Environmental Case Law Update (As of Feb. 26, 2015) — Gravel2Gavel Construction & Real Estate Law Blog — March 3, 2015 https://www.gravel2gavel.com/amp/environmental-case-law-update-as-of-feb-26-2015/ [15] [17] [18] Calif.'s Foie Gras Ban Struck Down by Federal Judge https://archive.findlaw.com/blog/califs-foie-gras-ban-struck-down-by-federal-judge/ [19] [31] [32] [33] [42] California foie gras ban goes into effect after Supreme Court rejects challenge - Los Angeles Times https://www.latimes.com/business/la-fi-foie-gras-prohibition-court-ruling-20190107-story.html [20] [21] [22] [23] [24] [26] [27] [103] [104] Appeals court revives California ban on foie gras | Reuters https://www.reuters.com/article/world/us/appeals-court-revives-california-ban-on-foie-gras-idUSKCN1BQ29Z/ [28] [29] [36] [39] [40] [72] [73] [74] [75] [76] [79] [84] [85] [86] [105] [107] [108] [129] Chefs react angrily as federal appeals court upholds California ban on foie gras - Los Angeles Times https://www.latimes.com/local/lanow/la-me-ln-foie-gras-9th-circuit-20170915-story.html [34] [35] [53] Foie gras from out of state can now be served in California - CBS News https://www.cbsnews.com/news/foie-gras-ban-lifted-in-california/ [43] [44] [45] [54] [59] [60] [61] [106] California Authorities Prepare to Not Really Bother to Enforce Foie Gras Ban https://reason.com/2012/06/26/california-authorities-prepare-to-not-re/ [46] [47] [48] [122] [123] Entrepreneur Backs Law that Will Close His Doors https://www.inc.com/news/articles/200509/foiegras.html [49] [89] [90] [91] [92] [100] Investigations | Farm Sanctuary Blog https://blog.farmsanctuary.org/category/investigations/ [50] California Foie Gras Fans Seek to Beat Curb as Ban Begins https://www.bloomberg.com/news/articles/2012-06-26/california-foie-gras-fans-seek-to-duck-curb-as-ban-begins [55] [PDF] Foie Gras Ban in California - GGU Law Digital Commons https://digitalcommons.law.ggu.edu/cgi/viewcontent.cgi?article=2134&context=ggulrev [57] [58] [62] [63] [64] [65] [66] Animal Legal Defense Fund v. LT Napa Partners LLC, | Animal Legal & Historical Center https://www.animallaw.info/case/animal-legal-defense-fund-v-lt-napa-partners-llc [67] [68] [69] [70] [71] [128] Foie Gras Lawsuit Against Napa’s La Toque Dismissed - Eater SF https://sf.eater.com/2019/8/28/20837061/la-toque-foie-gras-napa-california-lawsuit-animal-legal-defense-fund-dismissed [77] [78] [115] [116] [117] [118] [124] [125] [126] In favor of foie gras -- Ken Frank speaks out - Los Angeles Times https://www.latimes.com/archives/blogs/daily-dish/story/2012-04-11/in-favor-of-foie-gras-ken-frank-speaks-out [87] California Federal Court Serves Up a Win to Foie Gras Producers – Animal Law Developments https://blogs.duanemorris.com/animallawdevelopments/2020/07/17/california-federal-court-serves-up-a-win-to-foie-gras-producers/ [88] New Video Footage Exposes Horrifying Animal Cruelty at French ... https://mercyforanimals.org/blog/new-video-footage-exposes-horrifying-animal/ [93] [94] Victory for birds: U.S. Supreme Court upholds California foie gras ban - SPCA de Montréal https://www.spca.com/en/victory-for-birds-u-s-supreme-court-upholds-california-foie-gras-ban/ [97] Kamala Harris appeals court ruling against California foie gras ban https://www.sacbee.com/news/politics-government/capitol-alert/article9311378.html [98] [99] California's Foie Gras Ban Reinstated by US Ct. of Appeals! - spcaLA https://spcala.com/californias-foie-gras-ban-reinstated-by-us-ct-of-appeals/ [101] [PDF] Foie Gras and the Politics of Food - Chapter 1 - Princeton University http://assets.press.princeton.edu/chapters/s10708.pdf [102] Notes on Michaela DeSoucey's Contested Taste https://ngathanblog.wordpress.com/2019/04/11/notes-on-michaela-desouceys-contested-taste/ [109] California Bans on Pork, Foie Gras, Shark Fins, and Eggs by Ernesto ... https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3082594 [110] [PDF] Why State and Local Efforts to Ban Foie Gras Violate Constitutional ... https://aglawjournal.wp.drake.edu/wp-content/uploads/sites/66/2016/09/agVol12No2-Harrington.pdf [111] Part II: All duck or no dinner - The River Reporter https://www.riverreporter.com/stories/part-ii-all-duck-or-no-dinner,49615 [112] Hudson Valley foie gras producers sue NYC over ban - Times Union https://www.timesunion.com/hudsonvalley/news/article/Hudson-Valley-foie-gras-producers-sue-NYC-over-17194770.php [113] NY State Supreme Court Rejects Foie Gras Ban https://www.specialtyfood.com/news-media/news-features/specialty-food-news/ny-state-supreme-court-rejects-foie-gras-ban/ [114] California Foie Gras Ban Survives Final Challenge https://awionline.org/awi-quarterly/spring-2019/california-foie-gras-ban-survives-final-challenge [119] [PDF] Ninth Circuit Tips the Dormant Commerce Clause Scales in Favor of ... https://digitalcommons.pepperdine.edu/cgi/viewcontent.cgi?article=2604&context=plr [120] [PDF] one toke too far: the demise of the dormant commerce clause's ... https://bclawreview.bc.edu/articles/480/files/63abe9a265eb8.pdf [121] [PDF] A Wild Goose Chase: California's Attempt to Regulate Morality by ... https://digitalcommons.lmu.edu/cgi/viewcontent.cgi?article=1687&context=ilr