In Aurora Dairy Corp. Organic Milk Marketing & Sales Practices Litigation v. Aurora Organic Dairy (8th Cir. 2010) 621 F.3d 781, the Eighth Circuit concluded state consumer law claims against a certified milk producer for mislabeling nonorganic milk as organic were impliedly preempted because the lawsuit conflicted with federal law establishing national organic labeling standards. (Id. at p. 796.) The Eighth Circuit reasoned that based upon the OFPA's purpose and structure, compliance with the Act and certification, which permitted the dairy to label its product as "organic," were not separate requirements. Because the certified operations were authorized to label and sell organic products, state law claims challenging violations of the Act implicated federal certification and were not independently enforceable in a state consumer lawsuit. (621 F.3d at p. 796.) The Aurora Dairy court explained the purpose articulated in the OFPA, that is, " 'to establish national standards governing the marketing of certain agricultural products as organically produced products,' would be deeply undermined by the inevitable divergence in applicable state laws as numerous court systems adopt possibly conflicting interpretations of the same provisions of the OFPA and NOP." (Aurora Dairy, supra, 621 F.3d at p. 796.) Rather than achieving the congressional purpose to " 'assure consumers that organically produced products meet a consistent standard,' " if permitted to proceed, state consumer lawsuits would have the opposite result, creating " 'consumer confusion and troubled interstate commerce.' " (Id. at pp. 796-797.) The court acknowledged that state lawsuits might assure consumers they are buying organic, an argument advanced by Quesada, but such assurances actually undermine Congress's purpose to establish national standards. (Ibid.)