U.S. District Court Judge Lorna Schofield of the Souther District of New York dismissed a lawsuit by plaintiffs The Art and Antique Dealers League of America, Inc. and The National Antique and Art Dealers Association of America alleging that that New York Environmental Law §11-0535-a (State Ivory Law)---restricting the physical display for sale of items made from ivory (Display Restriction)---is preempted by the federal Endangered Species Act (ESA).

Schofield further granted the commissioner of the New York State Department of Environmental Conservation's motion for summary judgment on plaintiffs' claim that the State Ivory Law violates free speech rights guaranteed by the First Amendment.