J.S. West Inc. based in Modesto, Calif., filed a lawsuit on December 8, 2010, requesting a Fresno County Superior Court to establish quantitative requirements for cage size and hen density pursuant to California Proposition 2, which was passed in November 2008. J.S. West contends that the wording of Proposition 2 is vague.

Recently the company commissioned a European-style cage system that complies with standards in the European community. Due to uncertainty regarding Proposition 2, expansion and upgrading facilities in the State of California have been suspended since there is no certainty as to what will be required when the Proposition takes effect in January 2015.


Currently the HSUS claims that enriched cages do not conform to Proposition 2, but the AHA has developed a certification program for this system.