A compliance battle between the California Privacy Protection Agency and
The petition, filed in Sacramento County Superior Court, marks the first time the regulator has publicly disclosed an active investigation, which began in 2024. The farming supplies chain has refused to comply with the agency’s subpoena issued in January 2025, the petition obtained by Bloomberg Law alleges.
Tractor Supply’s challenge of the CPPA’s power is the first to reach a California court in the two years since the nation’s only privacy agency obtained its enforcement authority. The struggle between the Fortune 500 company and the enforcer stems from disagreements over how much material investigators can request, the agency said.
Tractor Supply declined to comment because of the “ongoing legal proceeding.” Its outside counsel Greenberg Traurig didn’t immediately respond to a request for comment.
According to the petition, Tractor Supply contends that providing information dating back to 2020 would be “overbroad” and “logistically too burdensome.” The company allegedly argued that its data privacy practices prior to 2023 “fall outside the scope of the agency’s enforcement authority.”
“After months of dragging its feet, Tractor Supply ultimately refused to answer questions about its business practices before January 1, 2023—leaving an evidentiary gap of three years from the law’s operative date,” the petition said.
The agency gained its enforcement authority July 2023, empowering it to implement and enforce the California Consumer Privacy Act, which went into effect in 2020. That same year, voters approved amendments to the CCPA, with the California Privacy Rights Act, which added new privacy protections and went into effect in January 2023.
The agency argues that it has jurisdiction over determining whether violations happened prior to 2023. Companies should have been complying with state privacy law starting in 2020, even if the statute has been amended since then, it said.
“Although regulations implementing aspects of the law followed over time, including in 2020, 2021, and 2023, any changes in the law do not abrogate the Agency’s authority to investigate possible violations,” the petition said.
Investigation Timeline
Agency officials launched an investigation in early 2024 into Tractor Supply’s data practices following a complaint by a Placerville, California, resident. The probe identified several instances of potential non-compliance with the state’s privacy law, including failure to update its privacy policy since 2021, failure to provide proper notices to consumers, disregard of users’ requests to opt out, and lack of avenues for consumers to exercise their privacy rights, according to the petition.
Regulators granted the company three extensions to respond. The company twice in March responded with information about its current privacy practices. However, Tractor Supply repeatedly failed to give any details about its privacy practices before 2023, the agency said. In May, the company objected for the first time to the subpoena’s request seeking information covering a five-year period.
The agency said it gave the rural lifestyle retailer—with annual revenue of more than $14 billion and more than 90 stores in California—until July to comply with the subpoena. It said Tractor Supply showed no signs of wanting to comply, which prompted the legal action.
In re: Investigation of Tractor Supply Company, Cal. Super. Ct., No. 25CV018464, petition filed 8/6/25
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