Justia Agriculture Law Opinion SummariesArticles Posted in Agriculture Law
Wilcox v. Security State Bank
The Supreme Court affirmed the decision of the district court granting summary judgment in favor of Security State Bank (SSB) on Plaintiff's claims and SSB's breach of contract counterclaim, holding that there was no error.When Plaintiff defaulted on several agricultural loans she had obtained from SSB, SSB foreclosed on some of the collateral Plaintiff pledged to secure those loans. Plaintiff then brought this action, alleging, among other things, negligent lending and negligent advising. SSB counterclaimed, alleging, among other things, breach of contract. The district court granted summary judgment in favor of SSB on all claims. The Supreme Court affirmed, holding (1) this Court declines to recognize new causes of action for negligent lending or negligence advising; (2) there were no questions of material fact barring summary judgment on Plaintiff's breach of good faith and fair dealing claim; and (3) the district court did not err in finding that equitable defenses did not preclude entering summary judgment in favor of SSB on his counterclaim for breach of contract. View "Wilcox v. Security State Bank" on Justia Law
Posted in: Agriculture Law, Banking, Contracts, Wyoming Supreme Court
Indemnity Insurance Co. of North America v. Westfield Insurance Co.
Sandstone operated large-scale swine farms in Scott County. Its owner also owned Red Oak. In 2007-2008, Westfield insured Sandstone. After 2008, Indemnity insured Sandstone. Star provided insurance to Red Oak. Sandstone was named as an additional insured under Star’s policy in 2009. In 2010, neighbors brought private nuisance claims against Sandstone in Illinois state court (“Marsh action”). Sandstone notified the three insurance companies. Each agreed to defend Sandstone, subject to a reservation of rights. Indemnity, citing a coverage exclusion for claims involving ”pollutants,” sought a declaratory judgment that it had no duty to defend. Sandstone withdrew its tender of defense to Indemnity, which dismissed its suit without prejudice. Star and Westfield split the defense of the Marsh action. An Illinois appellate court held that odor claims involving a hog facility are not “traditional environmental pollution” and are not excluded under insurance policy pollution exclusions, which foreclosed Indemnity’s earlier argument. Sandstone notified Indemnity, which filed another federal declaratory judgment action. In the Marsh action, a jury returned a verdict in favor of Sandstone. Westfield and then sought reimbursement of their defense costs.Reversing the district court, the Seventh Circuit ruled in favor of Indemnity. Its insurance is "excess" and Star had a duty to defend, so Indemnity’s “other insurance” provision relieves it of any duty to defend Sandstone. Indemnity is not estopped from asserting that defense because it promptly responded to Sandstone’s tender of defense. View "Indemnity Insurance Co. of North America v. Westfield Insurance Co." on Justia Law
Quality Plus Feeds, Inc. v. Compeer Financial, FLCA
The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment for an agricultural supplier in its foreclosure action to recover the amount of its unpaid bills from the sale proceeds of the two dairy farms it furnished with feed, holding that the supplier was entitled to summary judgment for the most part.The farms at issue were related but separate legal entities. The supplier did not receive payment for the feed, and later the farms closed down and all the remaining cows and milk were sold. The supplier brought a foreclosure action under the agricultural supplier's lien statute. The trial court granted summary judgment for the supplier, thus rejecting the arguments of a finical institution that had a larger unpaid loan balance and a previously perfected blanket lien as to both farms. The Supreme Court reversed in part, holding (1) the supplier was entitled to summary judgment on the financial institution's affirmative defenses; and (2) the financial institution was entitled to summary judgment as to the milk proceeds generated by a third dairy farm. View "Quality Plus Feeds, Inc. v. Compeer Financial, FLCA" on Justia Law
Posted in: Agriculture Law, Iowa Supreme Court, Real Estate & Property Law
Bachman Sunny Hill Fruit Farms v. Producers Agriculture Insurance Co.
Bachman Farms grows apples in Ohio and protected its 2017 crop with federally reinsured crop insurance from Producers Agriculture. When farmers and private insurers enter a federally reinsured crop insurance contract, they agree to common terms set by the Federal Crop Insurance Corporation (FCIC), including a requirement that the parties arbitrate coverage disputes. In those proceedings, the arbitrator must defer to agency interpretations of the common policy. Failure to do so results in the nullification of the arbitration award. Bachman lost at its arbitration with Producers Agriculture and alleged that the arbitrator engaged in impermissible policy interpretation. Bachman petitioned to nullify the arbitration award.The Sixth Circuit affirmed the dismissal of the suit. The petition to nullify did not comply with the substance or the three-month time limit of the Federal Arbitration Act (FAA), 9 U.S.C. 12. When a dispute concerning federally reinsured crop insurance involves a policy or procedure interpretation, the parties “must obtain an interpretation from FCIC.” Bachman did not seek an interpretation from FCIC but went directly to federal court to seek nullification under the common policy and its accompanying regulations—an administrative remedy—rather than vacatur under the FAA. View "Bachman Sunny Hill Fruit Farms v. Producers Agriculture Insurance Co." on Justia Law
Trosen, et al. v. Trosen, et al.
Jeff Trosen appealed a judgment and amended judgment awarding damages for a breach of contract claim to the Estate of Shirley Trosen and the Trosen Family Trust and dismissing Jeff’s counterclaim and third-party complaint. A dispute arose over Jeff’s lease of farmland from Shirley. The lease covered the farming seasons of 2017 through 2022. Partial payments were made in 2020 and 2021, leaving balances owed for those years. Shirley and the Trust sued Jeff for breach of contract and to cancel the lease. Jeff argued the district court erred in granting summary judgment on the breach of contract claim and by dismissing his counterclaim and third-party complaint. Finding no reversible error, the North Dakota Supreme Court affirmed the judgments. View "Trosen, et al. v. Trosen, et al." on Justia Law
Public Water Supply District No. 1 of Greene Co v. City of Springfield, Missouri
=Public Water Supply District No. 1 of Greene County, Missouri (“PWSD”) and the City of Springfield, Missouri (the “City”) filed cross motions for summary judgment, and the district court1 granted summary judgment in favor of the City. The district court also denied PWSD’s subsequent motion to alter or amend the judgment under Rule 59(e) of the Federal Rules of Civil Procedure. PWSD appealed these decisions. PWSD asserts its claims are timely under the continuing-violations doctrine because the City continues to provide water to customers within the Disputed Subdivisions. The Eighth Circuit affirmed the finding that PWSD’s claims are time-barred. Here, it is undisputed that the City began serving each of the Disputed Subdivisions in or before 1994. Based on the principles set forth above, a § 1926(b) violation must occur (and the statute of limitations accrues) when a municipality begins providing service to a new subdivision, and “not when it continues to do so.” Contrary to PWSD’s contention, it is not a continuing violation, and the statute of limitations does not reset when a municipality continues to add and provide service to customers in a subdivision it already serves. View "Public Water Supply District No. 1 of Greene Co v. City of Springfield, Missouri" on Justia Law
Spring Valley Produce, Inc., et al v. Nathan Aaron Forrest, et al
Appellant Spring Valley Produce, Inc. (SVP) is a creditor of Chapter 7 debtors Nathan and Marsha Forrest (the Forrests). The Forrests owe a pre-petition debt for produce which they are seeking to discharge. SVP initiated this adversary proceeding, seeking a declaration that the debt was nondischargeable under Section 523(a)(4). The bankruptcy court granted the Forrests’ motion to dismiss and held that Section 523(a)(4) does not apply to Perishable Agricultural Commodities Act (PACA) related debts. At issue on appeal is whether the Bankruptcy Code’s exception to discharge in 11 U.S.C. Sections 523(a)(4) applies to debts incurred by a produce buyer who is acting as a trustee under PACA. The Eleventh Circuit affirmed the bankruptcy court’s order dismissing SVP’s claims because Section 523(a)(4) does not accept debts incurred by a PACA trustee from discharge. The court explained debts incurred by a produce buyer acting as a PACA trustee are not excepted from discharge under Section 523(a)(4). While a PACA trust does identify a trustee, beneficiary, and trust res, thus satisfying the first step of our analysis, it does not impose sufficient trust-like duties to fit the narrow definition of a technical trust under Section 523(a)(4). PACA does not impose the duties to segregate trust assets and refrain from using trust assets for a non-trust purpose, which are strong indicia of a technical trust. Instead, a PACA trust more closely resembles a constructive or resulting trust, which do not fall within Section 523(a)(4)’s exception to discharge. View "Spring Valley Produce, Inc., et al v. Nathan Aaron Forrest, et al" on Justia Law
Vanegas v. Signet Builders, Inc.
Vanegas, a Mexican citizen, was hired by Signet, a nationwide construction company, to work in the U.S. on an H-2A guestworker visa, which authorizes foreign workers to perform “agricultural” work in the U.S. on a temporary basis, if the proposed employer can show that there are too few domestic workers willing and able to do the work and that the use of guest-workers will not undercut local workers’ wages and working conditions, 8 U.S.C. 1101(a)(15)(H)(ii)(a); 1188(a)(1). Vanegas was assigned to build livestock structures on farms in Wisconsin and Indiana. He routinely worked more than 40 hours a week, but Signet did not pay him extra for his overtime hours.He filed a complaint under the Fair Labor Standards Act (FLSA) and moved for conditional certification of a collective action on behalf of all Signet H-2A workers who were exclusively assigned to construction work. The district court dismissed, finding that Vanegas was an agricultural worker, exempt from FLSA’s overtime protections, 29 U.S.C. 213(b)(1). The Seventh Circuit reversed. Work falls within the FLSA agricultural exemption only if it is both “performed by a farmer or on a farm” and if it “does not amount to an independent business.” Regulations establish a fact-intensive, totality-of-the-circumstances test to determine whether work performed on a farm is agricultural or is an independent business. Signet did not prove that the agricultural exemption applies. View "Vanegas v. Signet Builders, Inc." on Justia Law
Cook Inlet Fisherman’s Fund v. Alaska Dept. of Fish & Game, et al.
A nonprofit entity representing commercial fishers sued the Alaska Board of Fisheries and the Department of Fish and Game, alleging that the State’s fishery management practices in Cook Inlet were unjustified and violated federal law and national standards. The nonprofit sought to depose two current Fish and Game employees but the State opposed, arguing that all material facts necessary for a decision of the case were in the administrative record. The superior court agreed with the State and quashed the nonprofit’s deposition notices. The court also granted summary judgment in favor of the State, deciding that the Cook Inlet fishery was not governed by federal standards and that none of the nonprofit’s disagreements with the State’s fishery management practices stated a violation of statute or regulation. The nonprofit appealed. Finding no reversible error, the Alaska Supreme Court affirmed the superior court judgment. View "Cook Inlet Fisherman’s Fund v. Alaska Dept. of Fish & Game, et al." on Justia Law
Telematch, Inc. v. AGRI
Telematch, Inc. is a commercial vendor of agricultural data. In 2018 and 2019, it submitted to USDA seven FOIA requests for records containing farm numbers, tract numbers, and customer numbers. USDA withheld the numbers under Exemptions 3 and 6. But it released or offered to release a statistical version of the files in accordance with section 8791(b)(4)(B). It also released payment information for the 2018 Conservation Reserve Program pursuant to section 8791(b)(4)(A). Telematch sued to challenge the USDA’s withholding of the farm, tract, and customer numbers. Both parties moved for summary judgment and attached statements of material facts to their motions. The district court granted the government’s motion for summary judgment. The court held that USDA properly withheld the farm and tract numbers under Exemption 3, because the numbers are “geospatial information” covered by section 8791(b)(2)(B). Telematch appealed. The DC Circuit affirmed. The court explained that farm and tract numbers identify a specific area of farmland in a specific location. They serve as a shorthand reference to individual plots of land. In this respect, they are analogous to a street address or latitude and longitude coordinates. They are, therefore “geospatial information” properly withheld under section 8791(b)(2)(B). Further, the court explained it need not definitively resolve whether farm and tract numbers meet these two statutory definitions. Neither of them applies to section 8791. Thus, the court held that the USDA permissibly withheld the requested farm, tract, and customer numbers. View "Telematch, Inc. v. AGRI" on Justia Law