In a watershed moment for privacy enforcement in California, the California Privacy Protection Agency (CPPA) has turned to courts to enforce a regulatory investigation. On August 6, 2025, the CPPA filed a first of its kind judicial action seeking to compel Fortune 500 company Tractor Supply Co. to comply with an investigative subpoena.

While Tractor Supply is not the first company to come under fire recently, the CPPA has, until now, conducted its enforcement work entirely behind closed doors. This filing also marks the Agency’s first public disclosure of an ongoing investigation into a company.

According to the petition filed in the Sacramento Superior Court, the investigation stems from a complaint submitted by a California resident in early 2024 regarding Tractor Supply’s privacy practices. The Agency alleges that the company may have failed to meet several key obligations under the California Consumer Protection Act (CCPA), including updating its privacy policy, providing required consumer notices, and honoring consumer rights.

In January 2025, the Agency’s Enforcement Division served a subpoena on Tractor Supply seeking information about its privacy practices, including processing of consumer requests under the CCPA, its use of tracking technologies on its website, and its relationship with third parties who receive consumers’ personal information. The subpoena sought this information during the period between January 1, 2020, the date when the CCPA became operative, and the present.  

In its response to the subpoena, Tractor Supply declined to produce any documents or information predating January 1, 2023. The company argued that because the CPPA’s enforcement authority began in July 2023, it cannot compel the production of materials from before that time.

The CPPA disagrees. In its court filing, the Agency contends that the CCPA has been in effect since January 2020, and that businesses have been subject to its requirements since then. The change in enforcement authority from the California Attorney General to the CPPA, the Agency argues, does not limit its ability to investigate earlier conduct. The CPPA also emphasized that Tractor Supply had been granted several extensions but had still failed to comply, leaving the Agency no choice but to pursue judicial enforcement.

Tractor Supply, a national retailer with more than 90 stores in California and over $14 billion in annual revenue, is not a newcomer to compliance obligations. Yet its decision to challenge the CPPA’s request may reflect broader industry uncertainty about the scope of the Agency’s powers, particularly with respect to historical data. A positive outcome for the CPPA could lead to more aggressive investigatory tactics and increased demands on businesses to maintain and produce historical records.

The CPPA has made clear that this judicial action is not a finding of wrongdoing. Rather, it is a procedural step to enforce the Agency’s ability to conduct a full investigation. Nevertheless, the filing underscores the Agency’s willingness to escalate matters when businesses do not cooperate with its investigations.