First Circuit upholds CDC six-month age rule for imported dogs
On July 13, 2026, the U.S. Court of Appeals for the First Circuit affirmed a decision rejecting a challenge to a CDC foreign-quarantine regulation for imported dogs—keeping the rule that dogs must be at least six months old at the time of U.S. arrival.
The case, Bruno Project Rescue Inc. v. CDC (No. 25-1801), came to the First Circuit as an appeal from the U.S. District Court for the District of Massachusetts (Judge Denise J. Casper).
What the CDC rule requires
Under the CDC’s foreign-quarantine regulation, all dogs presented for admission into the United States must be at least six (6) months old at the time of their arrival. Dogs that do not meet the age requirement “shall be denied admission and returned to the country of departure.” The provision is codified at 42 C.F.R. § 71.51(f) and was adopted through the Federal Register’s notice-and-comment rulemaking process.
The lawsuit: statutory authority and APA review
Rescue organizations involved in moving puppies from Caribbean locations into the United States challenged the six-month minimum age requirement. They argued:
- Statutory authority: the challengers said the CDC’s age requirement exceeded what Congress authorized for CDC public-health quarantine actions.
- APA “arbitrary and capricious” review: they said the rule lacked a sufficient, reasoned basis in the administrative record.
How the district court ruled (and why)
In a June 18, 2025 memorandum and order, the District of Massachusetts granted the CDC summary judgment and denied the plaintiffs’ motion. The court concluded the six-month age requirement fits within the CDC’s statutory authority and that the agency explained its decision through the rulemaking record.
What the First Circuit added
In affirming, the First Circuit applied the Administrative Procedure Act framework for reviewing agency action. The court explained that its review is deferential when evaluating whether a decision was arbitrary or capricious, while also emphasizing that courts must independently decide whether the agency acted within its statutory authority.
On the merits, the appeals court upheld the CDC’s six-month age requirement and concluded the agency’s reasoning—reflected in the final rule—provided an adequate basis to justify the requirement under the applicable APA standards.
Real-world impact: compliance doesn’t change
This decision does not create a new requirement. Instead, it keeps the existing rule in effect—meaning the six-month threshold remains a key benchmark for lawful dog importation under the CDC framework.
For importers, brokers, handlers, and animal-rescue groups planning international transport, the practical takeaway is the same: the CDC rule looks to the dog’s age at the time of U.S. arrival. If the dog is not yet at least six months old, the regulation directs that the dog be denied admission and returned to the country of departure.
What to watch next
The First Circuit’s affirmance leaves the CDC regulation in place. Any further procedural steps would depend on whether the parties file additional requests after an appellate decision.
Sources
- First Circuit opinion (Bruno Project Rescue v. CDC, No. 25-1801)
- Federal Register final rule (89 FR 41726)
Look for updates to this story
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