Justia Agriculture Law Opinion Summaries

This case stemmed from FNS's permanent denial of an application from J&K to participate in the government's food stamp program, SNAP. The court held that the imposition of permanent ineligibility to participate in SNAP, as oppose to assessing a monetary penalty, was not arbitrary and capricious where J&K's ineligibility to participate in SNAP was based on its owner's involvement in a prior food stamp trafficking violation. Accordingly, the court affirmed the judgment. View "J & K Market Centerville v. United States" on Justia Law

Plaintiffs appeal from an order of the district court dismissing their complaint for failure to state a claim upon which relief could be granted. Plaintiffs argued that New York's Kosher Law Protection Act of 2004 (Kosher Act), N.Y. Agric. & Mkts. Law 201-a-201-d, violated the Establishment and Free Exercise Clauses of the First Amendment and was unconstitutionally vague. The court held that the Kosher Act did not violate the Establishment Clause because it neither advanced or impeded religion, had a secular purpose, and did not create an excessive entanglement between state and religion. The court further held that the Kosher Act did not violate the Free Exercise Clause because it was neutral, generally applicable, minimally burdensome, and had a rational basis. Finally, even under the strictest scrutiny, the inspection provision was not void for vagueness. Accordingly, the court affirmed the judgment. View "Commack Self-Service Kosher v. Hooker" on Justia Law

Plaintiffs, owners of two dairy operations, appealed the dismissal of their constitutional challenges to two provisions of the Milk Regulatory Equity Act of 2005 (MREA), 7 U.S.C. 608c. Plaintiffs alleged that the provisions, which subjected certain large producer-handlers of milk to contribution requirements applicable to all milk handlers, constituted a bill of attainder and violated the Equal Protection and Due Process Clauses. Because the court found that the MREA did not apply with specificity to affected persons, the court need not address whether it satisfied either of the remaining elements of a bill of attainder. Therefore, the court affirmed the district court's dismissal of plaintiffs' claim. In regards to plaintiffs' remaining arguments, the court held that mere disparity of treatment was not sufficient to state an equal protection violation. The court also found that the government provided an explanation that was not only rational on its face but also had been consistently recognized by the courts as legitimate. Further, plaintiffs failed to plead the threshold requirement of a due process claim: that the government had interfered with a cognizable liberty or property interest. Finally, the court found that the district court did not abuse its discretion by refusing to allow plaintiffs to file a supplemental complaint. Accordingly, the court affirmed the judgment of the district court. View "Hettinga v. United States" on Justia Law

In 1996 defendant and his cousin formed companies that bought, stored, and sold grain, and provided farming services. In 1999, the cousins obtained bank loan by falsely representing that valuable contracts existed for future grain deliveries from one company to the other and inflating balances of bank accounts by writing bad checks between accounts. Charged with loan fraud and check-kiting (18 U.S.C. 1344) that cost the bank more than $2.5 million, the cousin pled guilty. Defendant testified that the transactions were in good faith, but was convicted and sentenced to 70 months in prison and restitution in the amount of $1,967,055.30, the outstanding balance on the loans. The Seventh Circuit affirmed, rejecting arguments that the indictment was multiplicitous; that there was insufficient evidence of guilt beyond a reasonable doubt; that sentencing under 2009 guidelines violated the ex post facto clause; that loss and restitution amounts were miscalculated; that an enhancement for obstruction of justice was improper; and that the disparity between defendant’s sentence and that of his cousin was improper.View "United States v. Peugh" on Justia Law

Rabo Agrifinance and Rabo AgServices (collectively, Rabo) commenced a foreclosure action in 2009 on a mortgage granted by Connie and David Finneman (Finnemans) on 17,000 acres of farmland. Rabo commenced its action against Finnemans, Rock Creek Farms (RCF), and all parties who may have had an ownership or leashold interest in the land. Approximately forty-four defendants were listed in the complaint, including Ann and Michael Arnoldy (Arnoldys) and the U.S. as lienholders. The trial court eventually entered a decree of foreclosure in which it recognized RCF's owner's right of redemption. After a sheriff's sale, Ann Arnoldy redeemed from an assignee of the purchaser of the sheriff's certificate. The Arnoldys filed a motion to partially vacate the decree of foreclosure. The trial court granted the motion and vacated the decree of foreclosure recognizing RCF's redemption rights on the basis that RCF and its predecessors, Finnemans, waived those rights. RCF and Finnemans appealed. Arnoldys and the U.S. filed motions to dismiss the appeals for failure to serve the notice of appeal on the U.S. and a number of named parties. The Supreme Corurt dismissed Finnemans' and RCF's appeals for failure to serve their notices of appeal on each party to the action. View "Rabo Agrifinance, Inc. v. Rock Creek Farms" on Justia Law

The Trademark Trial and Appeal Board affirmed an examining attorney's refusal to register the trademark XCEED, in standard character form, for agricultural seed, citing the Lanham Act, 15 U.S.C. 1052(d). A previously-registered word and design mark for agricultural seeds consisted of the characters X-Seed in stylized form. The Federal Circuit affirmed, finding substantial evidence that the XCEED mark would likely cause confusion with the X-Seed mark. View "In re Viterra" on Justia Law

McKesson, a United States company, claimed that after the Islamic Revolution, the government of Iran expropriated McKesson's interest in an Iranian dairy (Pak Dairy) and withheld its dividend payments. McKesson filed its complaint in 1982, the case reached the court on five prior occasions, and was remanded by the court for numerous trials by the district court. At issue was whether the court had jurisdiction over McKesson's claim and whether any recognized body of law provided McKesson with a private right of action against Iran. The court affirmed the district court's holding that the act of state doctrine did not apply in this case. While the court reversed the district court's holding that McKesson could base its claim on customary international law, the court affirmed the district court's alternative holding that the Treaty of Amity, construed as Iranian law, provided McKesson with a private right of action, and the court further affirmed the district court's finding that Iran was liable for the expropriation of McKesson's equity interest in Pak Dairy and the withholding of McKesson's dividend payments. Finally, the court reversed the district court's award of compound interest and remanded for calculation of an award consisting of the value of McKesson's expropriated property and withheld dividends plus simple interest. View "McKesson Corp., et al. v. Islamic Republic of Iran" on Justia Law

The Board of Patent Appeals and Interferences declared an interference between the claims of a patent belonging to Pioneer and those of a pending application owned by Monsanto. The claims concern transgenic corn. After the Board concluded that Monsanto was not time-barred under 35 U.S.C. 135(b)(1) and that its claims were entitled to seniority, Pioneer stipulated to judgment against it and the Board canceled Pioneer's claims. The Federal Circuit affirmed. View "Pioneer Hi-Bred Int'l, Inc. v. Monsanto Tech., LLC" on Justia Law

The Lesiaks were farmers who suffered a reduced corn yield, allegedly due to the overapplication of herbicide to their crops by Central Valley Ag Cooperative, Inc. (CVA). The Lesiaks filed this action against CVA, asserting multiple theories of recovery, including negligence, breach of implied warranty of merchantability, and breach of implied warranty of services. The district court granted summary judgment in favor of CVA on the implied warranty of services and negligence claims. Following the Lesiaks' presentation of their case, the district court granted CVA's motion for a directed verdict on the Lesiaks' remaining claim for breach of implied warranty of merchantability. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the district court erred in granting a directed verdict in favor of CVA as there was evidence in the record which would allow a jury to find the overapplication of the herbicide damaged the Lesiaks' fields and also to reasonably estimate the extent of the damage; and (2) the district court erred in granting summary judgment on the Lesiaks' negligence claim, as it was not barred by the economic loss doctrine. View "Lesiak v. Central Valley Ag Coop., Inc." on Justia Law

A client complained to the Grain Inspection, Packers and Stockyard Administration about the broker purchasing his own stock for customers. Following a remand, the USDA imposed a 16-month suspension on his registration under the Packers and Stockyards Act, 7 U.S.C. 181-229. The Eighth Circuit affirmed. The judicial officer adequately considered the nature of the violations in relation to the remedial purposes of the PSA. The suspension was not too harsh, given the circumstances of the violation. View "Syverson v. U.S. Dep't of Agric." on Justia Law