Justia Agriculture Law Opinion Summaries

Plaintiff filed a putative class action arguing that the sodium content in a "serving" of sunflower seeds must include the sodium contained in the edible coating. The court concluded that, because the coating is edible and is intended to be edible, the portion of the edible coating on the shell of the sunflower seed must be accounted for in the calculation of the sodium content. Because plaintiff's state-law claims, if successful, would impose no greater burden than those imposed by federal law, her state law claims were not preempted. Accordingly, the court reversed the district court's grant of defendant's motion to dismiss. View "Lilly v. ConAgra Foods" on Justia Law

Greving has lived and farmed in southeastern Wisconsin since 1971. In 2003 he began contracting to sell his grain to Northern Grain, an Illinois-based grain buyer. Northern Grain claimed that Greving repudiated several contracts formed years after the parties first began contracting and sought almost $1 million in damages. When Greving refused to arbitrate, Northern Grain sought an order compelling arbitration. The Illinois district court dismissed for lack of personal jurisdiction. The Seventh Circuit affirmed. Greving lacks minimum contacts with Illinois that would permit the district court, consistent with the due process clause, to exercise specific personal jurisdiction over him. Greving only set foot in Illinois once, to attend a seed-corn meeting in 2003, months before the parties entered into the first of their contracts, where he met Wilson, who became his contact with Northern Grain. Even assuming that his attendance at the meeting would enter the “personal-jurisdiction calculus for the later-formed contracts at issue,” there is no indication that Greving attended the meeting in an effort to find grain buyers. Virtually everything else about Greving’s contractual relationship with Northern Grain was based in Wisconsin. View "N. Grain Mktg., LLC v. Greving" on Justia Law

Plaintiffs filed suit against their sons, their former attorney, a limited liability company (SMP), and others, challenging the validity of their mortgages delivered to SMP. Without first seeking mediation, SMP counterclaimed to foreclose on a mortgage granted by Plaintiffs on their agricultural property. The district court foreclosed the mortgage and denied Plaintiffs' motion to quash or stay the sheriff's sale. The court of appeals reversed, concluding that the district court lacked subject matter jurisdiction to foreclose on the agricultural property because SMP had not first obtained a mediation release as required by Iowa Code 654A.6(1). The Supreme Court reversed, holding that SMP was not required to obtain the mediation release prior to filing a counterclaim to foreclose its mortgage. View "Schaefer v. Putnam" on Justia Law

Christine and David Colburn leased property from Robert Hartshorn and agreed to care for Hartshorn's cattle. Neither the terms of the cattle care agreement or the lease agreement were reduced to writing. After a dispute, the Colburns served on Hartshorn an agister's lien for caring for Hartshorn's cattle. The Colburns also brought an action to recover amounts due for their care of Hartshorn's cattle and to foreclose the lien. Ultimately, the Colburns received a court order to sell the calves. The circuit court ruled that the Colburns were entitled to one half the net calf sale proceeds from the sale but found the agister's lien invalid under the terms of the parties' implied contract because the cattle were cared for on Hartshorn's land and not the Colburns' land. The Supreme Court reversed, holding that nothing in the state's laws governing agister's liens defeats their validity when cattle are entrusted to a caretaker on the cattle owner's land. Remanded. View "Colburn v. Hartshorn" on Justia Law

Pursuant to an oral agreement with Defendant, Plaintiff kept his beefalo cattle herd on Defendant's ranch. After a dispute arose between the parties regarding the oral agreement, Defendant asserted a lien for payments allegedly owed under the oral agreement. Plaintiff filed a complaint and petition for release of his cattle, asserting that the lien was knowingly false and groundless and that Defendant wrongfully converted the beefalo herd. The jury found that Defendant was liable for conversion of Plaintiff's cattle but that Defendant was entitled to the lien claimed for feed and pasturage from the time Defendant asserted the lien on the cattle until their court-ordered release. Defendant filed a motion for a new trial, claiming the verdict was inconsistent because he could not be liable for conversion of Plaintiff's beefalo herd if he was entitled to a lien against the same. The district court denied Defendant's motions and entered a final judgment incorporating the jury's verdict. The Supreme Court reversed, holding that the district court abused its discretion in denying Defendant's motion for new trial because the verdict was contrary to law and could not be reconciled. Remanded for a new trial. View "McTiernan v. Jellis" on Justia Law

Phillip Morris sought review of the USDA's decision regarding the implementation of the Fair and Equitable Tobacco Reform Act (FETRA), 7 U.S.C. 518 et seq. Phillip Morris challenged the USDA's decision to use 2003 tax rates instead of current tax rates in calculating how these assessments were to be allocated across manufacturers of different tobacco products. The court concluded that USDA's decision was a permissible interpretation of FETRA; there was no clear indication in the text of the statute, or in Congress's prior or subsequent action, that Congress intended for USDA to take a different course; and there was similarly no basis for concluding that USDA filled that gap with an unreasonable interpretation. Accordingly, the court affirmed the district court's grant of USDA's motion for summary judgment. View "Philip Morris USA, Inc. v. Vilsack" on Justia Law

Plaintiff, which owned and operated a ranch, hired Defendant as a custom seeder to seed a barley crop grown under a contract with Circle S Seeds of Montana, Inc. The crop could not be harvested on schedule, and a heavy October snow later destroyed the crop. Plaintiff sued Defendant for breach of contract, alleging that crop did not ripen in time because of improper seed placement. The district court denied and dismissed with prejudice Plaintiff's breach of contract claim, concluding that Defendant did not materially breach its contract with Plaintiff. The Supreme Court affirmed, holding that the district court did not err in finding Defendant did not breach the contract by failing to object to rocky field conditions or by failing to achieve uniform depth of seed placement. View "CNJ Distrib. Corp. v. D & F Farms, Inc." on Justia Law

Bayer’s patent concerns genetically modifying plants to confer resistance to a common herbicide (2,4-D) by inserting a particular DNA segment into plant cells, which reproduce to create new cells that contain that gene. Those cells produce an enzyme that catalyzes a biochemical reaction with 2,4-D in which the herbicide is broken down into something harmless to the plant. A plant with the gene survives 2,4-D application while surrounding weeds do not. At the time of the patent application, the inventors had sequenced one gene coding for one enzyme, using a test supposedly capable of finding other, similar genes. In writing the application, they claimed a broad category based on the function of the particular enzyme, defining the category by using a term with established scientific meaning. Years before the patent issued, experiments showed that the term did not apply to the particular enzyme whose gene was sequenced, but Bayer did not change its claim language. When Bayer sued Dow for infringement, Bayer recognized that the term’s established scientific meaning, did not cover the accused product, which was, itself, different from the enzyme whose gene Bayer’s inventors had sequenced. Bayer argued for broad functional claim construction. The district court entered summary judgment of noninfringement, citing particularly the great breadth of the asserted functional construction. The Federal Circuit affirmed. View "Bayer CropScience AG v. Dow AgroSciences, LLC" on Justia Law

During the 1970s and 1980s, American Agri‐Corp organized several limited partnerships, for which the company served as general partner. American solicited high‐income individuals to serve as limited partners, investing in supposed agricultural ventures. According to the IRS, the actual purpose was to shelter the income of limited partners from taxation. Plaintiffs were each limited partners (or spouses) in at least one partnership that was audited by the IRS during the mid‐1980s. Several years later, the IRS concluded that the partnerships were, essentially, tax‐avoidance schemes .In 1990 and 1991, the IRS issued Final Partnership Administrative Adjusts for the partnerships and disallowed several listed farming expenses and other deductions for the 1984 or 1985 tax years. The Tax Court consolidated cases, held that the IRS action was not time‐barred, and determined that the partnerships had engaged in “transactions which lacked economic substance” that resulted in a substantial distortion of income and expense. The district court held that it lacked subject‐matter jurisdiction over the taxpayers’ claims that the assessments were untimely and improperly included penalty interest. The Seventh Circuit affirmed. The determinations at issue are attributable to partnership items over which courts lack subject‐matter jurisdiction. View "Acute Care Specialists II v. United States" on Justia Law

Certain amplified music concerts were conducted on farm land in a rural county. The county board of zoning appeals later ordered the business owners who hosted the concerts to limit the concerts to one per year, but the business owners defied the order. Plaintiff, a neighborhood property owner, filed suit seeking to enforce the zoning authority's decision and to abate the concerts as a common-law nuisance. The trial court granted Defendants' motion to dismiss, concluding (1) the concerts were exempted from local land use regulations because they qualified as "agriculture"; and (2) the Tennessee Right to Farm Act (Act) precluded nuisance liability. The Supreme Court reversed, holding (1) the concerts were not "agriculture" for the purpose of the zoning laws; and (2) the Act did not apply to the music concerts, and Plaintiff presented a prima facie case of common-law nuisance. Remanded. View "Shore v. Maple Lane Farms, LLC" on Justia Law