Justia Agriculture Law Opinion Summaries

Lakeside appealed from the district court's grant of summary judgment in favor of Producers on Lakeside's state-law claim for fraudulent misrepresentation, negligent misrepresentation, and unjust enrichment involving payment for the feed and care of the hogs at issue. The court affirmed the district court's grant of summary judgment in favor of Producers on Lakeside's fraudulent misrepresentation claim where Lakeside was unable to establish that Producers made any false representations; affirmed the district court's grant of summary judgment on the fraudulent nondisclosure claim where Producers was under no legal obligation to disclose information to Lakeside; held that the district court did not abuse its discretion in excluding Lakeside's expert testimony where such testimony was not needed to inform the district court on the legal issues; affirmed the district court's grant of summary judgment in favor of Producers on the issue of negligent misrepresentation where Producers was not in the business or profession of supplying information or guidance to Lakeside but rather the two conducted themselves at arm's length; and held that it was not unjust to allow Producers to retain the benefit of these particular happenings when a shortfall existed, as it was not inequitable to allow a contracting party the right to fulfillment of contractual obligations, which in this case included the payment of fees contemplated by the Hog Program. View "Lakeside Feeders, Inc. v. Producers Livestock Marketing, et al." on Justia Law

A hog producer with outstanding loans to Primebank went deeper into debt by purchasing feed on credit from Oyens Feed & Supply to fatten the hogs to market weight. The hog producer subsequently filed for bankruptcy. Primebank had a perfected security interest in the hogs to secure two promissory notes predating Oyen Feed's perfected agricultural supply dealer lien on the hogs. The hog producer filed an adversary proceeding to determine the priority of the liens. The bankruptcy court granted Primebank partial summary judgment on grounds that Oyens Feed failed to provide Primebank a certified request under Iowa Code 570A.2. Oyens Feed appealed the bankruptcy court's ruling to the U.S. district court, which then certified a question of law to the Supreme Court. The Court answered by holding that Primebank's prior perfected security interest in the hogs is trumped by Oyen Feed's agricultural supply dealer lien under Iowa Code 570A.5(3) to the extent of the enhanced value of the livestock presumptively attributable to the feed, even though the bank received no certified request before the feed was sold on credit. View "Oyens Feed & Supply, Inc. v. Primebank" on Justia Law

Bayer CropScience LP developed LibertyLink Rice (LLRice), a genetically engineered rice, which Bayer subsequently used in outdoor field tests. The USDA later found that trace amounts of LLRice in the U.S. long-grain rice supply. Due to the contamination, several countries slowed or banned the import of all American rice. Appellees, several rice farmers and farming entities, sued Bayer, claiming (1) Bayer was negligent in allowing the accidental release of LLRice into the nation's rice supply by not taking adequate precautions during field trials to prevent cross-pollination or the commingling of genetically modified rice seed with conventional seed; and (2) Bayer's negligence caused economic harm by driving down the market price for American long-grain rice. The circuit court awarded $5,975,605 in compensatory damages and $42,000,0000 in punitive damages to Appellees. The Supreme Court affirmed, holding that the circuit court did not err in (1) ruling that Ark. Code Ann. 16-55-208, which establishes limits on awards of punitive damages, is unconstitutional; (2) concluding that Appellees' claims were not barred by the economic-loss doctrine; (3) allowing certain expert testimony; and (4) rejecting Bayer's legal argument advanced in its motion for a directed verdict. View "Bayer CropScience LP v. Schafer" on Justia Law

Taxpayer, related corporations that operated a vertically-integrated poultry production business, sought an exemption from ad valorem taxes on five industrial personal property tax returns it filed with the State Tax Department, claiming it was exempt from such taxation under either the "subsistence of livestock" or the "farm" exemption under W. Va. Code 11-3-9-(a)(21), (28). The State Tax Commissioner concluded that Taxpayer was not entitled to either exemption. The trial court (1) ruled that Taxpayer was entitled to claim the "subsistence of livestock" exemption in connection with its hatchery operation but not with regard to personal property used at its live haul center and feed mill operation; and (2) concluded that none of Taxpayer's operation qualified for the "farm" exemption. The Supreme Court affirmed, holding that the trial court did not err in ruling that Taxpayer was not entitled to any exemptions from personal property taxation in connection with its commercial poultry operation other than the exemption afforded to its hatchery operation. View "Pilgrim's Pride v. Morris" on Justia Law

Jensen Family Farms, Inc. ("Jensen") sued the Monterey Bay Unified Air Pollution Control District ("District"), alleging that the District's Rules 220, 310, and 1010 were preempted by the federal Clean Air Act ("CAA"), 42 U.S.C. 7401 et seq.; Rules 220 and 310 violated certain provisions of California law; and the Rules violated Jensen's due process rights. Jensen moved for summary judgment and while it's motion was pending, the district court granted the California Air Resources Board's ("CARB"), California's air pollution control agency, motion to intervene. CARB and the District (collectively, "defendants") subsequently filed a motion for judgment on the pleadings pursuant to Federal Rule of Civil Procedure 12(b)(6). Jensen appealed the district court's judgment. The principal question in this case, among other questions, was whether the District's rules were preempted by the CAA. The court held that Rules 220 and 310 were not standards or other requirements related to the control of emissions and therefore, not preempted by CAA 209(e). The court also held that Rule 1010 did not apply to any "nonroad engines," as that term was used in the CAA and therefore, was not preempted under section 209(e). The court further held that there was no basis for Jensen's claim under Cal. Code Regs. tit. 17, 93116 or Cal. Code Regs. tit. 13, 2450 et. seq.; that the Rules did not violate Jenson's due process rights where it admitted that the Rules served the legitimate government interest in minimizing air pollution from diesel engines; and the Rules did not violate California Constitution, Article 13A because Jensen waived this argument in its complaint. Accordingly, the court affirmed the district court's judgment on the pleadings in favor of defendants.View "Jensen Family Farms, Inc. v. Monterey Bay Unified Air Pollution Control District, et al." on Justia Law

Several Nebraska farmers filed suit under 42 U.S.C. 1983, alleging their due process rights were violated when Nebraska officials ordered the farmers to cease drawing water from the Niobrara Watershed without providing a predeprivation hearing. The court agreed with the district court that the farmers have not suffered a deprivation of their property rights where the property right held by the farmers was expressly conditioned on the Nebraska Department of Natural Resources' (DNR) determination of watershed capacity. Therefore, the farmers had no legitimate claim to the water when the DNR determined that there was a scarcity and the issuance of Closing Notices was necessary to satisfy the needs of senior appropriators. The court also held that the district court was permitted to dismiss without prejudice the pendent state-law ultra vires claim in light of its grant of summary judgment on the section 1983 claim. View "Keating, et al. v. Nebraska Public Power District, et al." on Justia Law

A default judgment entered against the defendant, for failure to pay loans from the Department of Agriculture. On the day before property was to be sold at auction, the defendant filed a bankruptcy petition. The judge lifted the stay. The $322,000 proceeds from the sale were inadequate to pay the debt and the government has a deficiency judgment. The trial court denied a motion to set aside the sale and a request for an opportunity to redeem. The Seventh Circuit affirmed. Although the property has transferred to the buyers, who are not parties to the litigation, and their interests are secure, the case is not moot. The sale price, which was below the $513,000 appraisal price, did not "shock the conscience" so as to be invalid under Wisconsin law.View "United States v. Buchman" on Justia Law

Migrant workers who worked for defendant appealed a summary judgment in favor of defendant and against their complaint that defendant violated the Fair Labor Standards Act (Act), 29 U.S.C. 203(m). At issue was whether an employer that hired migrant farm workers through the H-2A visa program was entitled to wage credits under the Act for housing and meals that federal law required the employer to provide the workers. The court deferred to the Secretary of Labor's interpretation that defendant could not credit the cost of housing in the wages paid to the workers and agreed with defendant that it was entitled to wage credits for the costs of meals for the workers. The court also concluded that defendant was not liable under principles of agency law for the fees that third parties charged the workers related to their efforts to obtain employment with defendant. Accordingly, the court affirmed in part, reversed in part, and remanded. View " Ramos-Barrientos, et al. v. Bland, et al." on Justia Law

A family partnership purchased 749-acres for use as a farm. The entire farm enjoyed current-agricultural-use-valuation (CAUV) status until a seventy-acre parcel was transferred to Maralgate, LLC, after which the county auditor denied the CAUV application. Maralgate filed a complaint with the County Board of Revision, which also denied the application. The Board of Tax Appeals reversed and granted CAUV status. At issue on appeal was whether the parcel was under common ownership with the rest of the farm for purposes of Ohio Rev. Code 5713.30(A)(1) because almost sixty percent of the parcel had trees that were not grown for commercial purposes. The Supreme Court affirmed, holding (1) the parcel was under common ownership with the rest of the farm because the family partnership owned Maralgate; (2) the statute does not require that the trees in question be grown as a crop; and (3) a land survey showing how much of the parcel is devoted to different uses is required only if there is a commercial use of part of a parcel that is not an agricultural use, and, in this instance, those portions of the parcel not actively cultivated were not used for any commercial purpose. View "Maralgate, L.L.C. v. Greene County Bd. of Revision " on Justia Law

A 1935 settlement gives the tribe specific irrigation rights in the Gila River. The government filed another water rights claim on behalf of the tribe in 1979, resulting in a 2006 Arizona Supreme Court decree that the 1935 decree resolved all of the tribe's rights under all theories and that federal court was the proper forum for interpretation and enforcement of that decree. The Court of Federal Claims dismissed a claim against the United States for failure to secure and protect the tribe's water rights. The Federal Circuit affirmed, finding the claim barred by the six-year limitations period in 28 U.S.C. 2501. Rejecting an argument that the tribe was not on notice of its harm until the 2006 decision, the court stated that the plain terms of the 1935 decree indicated that the tribe would have no further rights and that the government was representing multiple parties.View "San Carlos Apache Tribe v. United States" on Justia Law