The Ninth Circuit Court of Appeals has rejected as moot an appeal for reconsideration brought by the Shaka Movement in an effort to reestablish a ban on genetically modified organisms (GMOs) approved by voters in Maui County, Hawaii. Robert Ito Farm v. Cnty. Of Maui, No. 15-15641 (9th Cir., order entered October 23, 2015). A federal court invalidated the statute in June 2015, finding that the ban exceeded county authority to impose fines. The unsigned appeals court opinion offered no further discussion beyond that the “motion to dismiss this appeal as moot is granted.” Additional information about the lower court’s ruling appears in Issue 571 of this Update.