Justia Agriculture Law Opinion Summaries

Plaintiffs, seasonal farm workers who relocated from Arizona to Oregon to work for Bear Creek Orchards, Inc. ("Bear Creek"), filed a class action lawsuit against Bear Creek alleging violations of the Migrant and Seasonal Agricultural Worker Protection Act and Oregon's minimum wage laws. At issue was whether certain on-site housing costs of seasonal farm workers could be credited toward the minimum wage set by Oregon law. Also at issue was whether Bear Creek violated Oregon law when it paid some of its workers a day later than it should have. The court held that Bear Creek violated Oregon law when it credited on-site housing costs towards its employees' minimum wage where on-site housing was necessary in order for Bear Creek to maintain an adequate workforce at the times and locations Bear Creek needed them. The court also held that Bear Creek violated Oregon law when it paid some of its workers the day after their last workday where the phrase in Oregon Revised Statutes 652.145, "whenever the employment terminates" was correctly interpreted to mean "on the last day the employee works."View "Elias Bobadilla-German, et al v. Bear Creek Orchards, Inc." on Justia Law

Debtors, owners and operators of a farm and ranch, appealed from the judgment of the bankruptcy court denying their discharge pursuant to 11 U.S.C. 727(a)(5). The court held that the bankruptcy court did not clearly err in finding that debtors failed to adequately explain the loss of cattle. Accordingly, the judgment denying debtors' discharge was affirmed. View "Allred v. Vilhauer, et al." on Justia Law

Defendant was convicted after a three-day jury trial of four counts of injecting fluids into deep wells without a permit, in violation of the Safe Drinking Water Act (SDWA), 42 U.S.C. 300h-2(b)(2). Defendant was also convicted of one count of making a "materially false" statement in a "matter within the jurisdiction" of the United States, in violation of 18 U.S.C. 1001(a)(2). Defendant timely appealed. The court affirmed Counts One through Four under section 300h-2(b)(2) and held that the government was required to prove only that defendant willfully injected water into a well more than eighteen feet deep without a permit, knowing that a permit was required under Idaho law; the reference in 40 C.F.R. 147.650(a)(7) to specific provisions of Idaho law, including those applicable to permitting, make clear that the entire Idaho permitting process was approved and incorporated into the SDWA; and that section 300h-2(b)(2) did not exceed Congress' authority under the Commerce Clause. The court affirmed Count Five under section 1001(a)(2) where defendant made a false statement in a matter within the jurisdiction of the United States. The court held that the district court did not abuse its discretion in holding that its limiting instruction and the stipulation cured any possible prejudice that might have been caused by the three references to "waste" and brief display. The court also held that testimony from a supervisor at the Idaho Department of Agriculture was used for the purpose of showing that defendant injected fluids "willfully" and that the testimony was a small part of the evidence presented to the jury that defendant acted "willfully." Thus, if there was any error in presenting the testimony, the error was harmless. Accordingly, the court affirmed the judgment. View "United States v. King" on Justia Law

The 605 and 247 patents cover aspects of genetically modified soybeans. The patent-holder sued one of its licensed seed producers, alleging infringement rather than breach of the agreement between the two. The district found infringement and awarded about $84,000. The Federal Circuit affirmed, rejecting an argument that patent rights were exhausted with respect to all of the soybean seeds that are present in grain elevators as undifferentiated commodity. The court also rejected an argument that plaintiff could not recover pre-complaint damages because it did not provide actual notice and did not mark or require growers to mark second-generation seeds in compliance with 35 U.S.C. 287(a). Defendant had actual notice. View "Monsanto Co. v. Bowman" on Justia Law

Plaintiffs, 134 farmers whose crops suffered as a result of the federal Bureau of Land Management's (BLM) use of the herbicide Oust, sued the federal government and Oust's manufacturer (DuPont). Both the jury and the district court allocated 60% of the fault to DuPont and 40% to the federal government. Both the government and DuPont appealed: the court resolved the government's appeal in this opinion and DuPont's appeal in a memorandum disposition filed simultaneously with this opinion. The court held that it lacked subject mater jurisdiction over plaintiffs' Federal Tort Claims Act (FTCA), 28 U.S.C. 2402, claims because plaintiffs filed their lawsuit one day after the FTCA's statute of limitations had run. Therefore, the court held that the district court erred by not dismissing the claims against the federal government. View "Adams, et al. v. United States, et al." on Justia Law

In 2007, Davison County adopted a county-wide plan to reassess agricultural structures. The County reassessed agricultural structures in four of its twelve townships that year. Donald and Gene Stehly, who owned agricultural structures in the four reassessed townships, initiated a declaratory judgment action, alleging that the plan to reassess four townships each year created an unconstitutional lack of uniform taxation within the county. The trial court concluded that the Stehlys' claim failed because they did not establish lack of uniformity within a single taxing district as required by the South Dakota Constitution. The Supreme Court affirmed, holding (1) townships are taxing districts under the Constitution, and (2) a reassessment plan that creates a temporary lack of uniform taxation among townships within a county is constitutional. View "Stehly v. Davison County" on Justia Law

Plaintiffs, California grape growers who purchased grapevines covered by the USDA's patents, brought this action to challenge the validity and enforceability of the USDA's patents on three varieties of grapes, as well as the conduct of the California Table Grape Commission (Commission) and the USDA in licensing and enforcing the patents. The court held that the district court correctly held that the USDA was a necessary party to plaintiffs' declaratory judgement claims based on the Patent Act, 35 U.S.C. 1 et seq. The court also held that the waiver of sovereign immunity in section 702 of the Administrative Procedure Act, 5 U.S.C. 500 et seq., was broad enough to allow plaintiffs to pursue equitable relief against the USDA on its patent law claims. The court further held that plaintiffs' claims were sufficient to overcome any presumption of regularity that could apply to a certain USDA employee who was one of the co-inventors of each of the three varieties of grapes. The court finally held that because plaintiffs failed to point to anything other than the issuance of a patent for the Sweet Scarlet grapes that would provide a plausible basis for finding that Sweet Scarlet grapes form a relevant antitrust market, the court upheld the district court's decision dismissing plaintiffs' antitrust claim. View "Delano Farms Co., et al. v. The California Table Grape Comm., et al." on Justia Law

In 2000, mushroom farmers and related entities formed a cooperative (EMMC) and established minimum pricing policies and programs to improve their market position. EMMC purchased properties and resold them with deed restrictions that prohibited mushroom farming. The Department of Justice invesigated and concluded that EMMC was an agricultural cooperative organized pursuant to the Capper- Volstead Act, 7 U.S.C. 291-92. In 2005, EMMC and DOJ entered into a consent judgment that required EMMC to nullify deed restrictions and prohibited it from imposing restrictions for 10 years. Soon after the consent judgment, private parties brought suits, alleging conspiracy in violation of the Sherman Act and Clayton Act. (15 U.S.C. 1, 2, 18). Unlike the DOJ action, the consolidated class action involved both the property purchase program and minimum pricing policies. The district court held that EMMC was not a proper agricultural cooperative under the Act because one member was not technically a grower of agricultural produce and that the uncontested facts revealed an impermissible price-fixing conspiracy with a non-member mushroom distribution company. The Third Circuit dismissed an appeal, holding that it lacked jurisdiction to hear the question on interlocutory appeal. View "In Re: Mushroom Direct Purchaser Antitrust Litigation" on Justia Law

In 2008, Olmsted County changed the property tax classification of farmland owned by Frederick Farms from agricultural-homestead to agricultural-nonhomestead property. The tax court denied Frederick Farms' petition to change the classification of the property back to agricultural homestead for taxes payable in 2009 and later. Frederick Farms appealed, arguing that it was operating a joint family farm venture with its sole shareholder, James Frederick, and that the County must classify the property as agricultural homestead because it was used by the joint family farm venture. The Supreme Court affirmed the decision of the tax court, concluding (1) that a joint family farm venture must own or lease, and not merely use, the property in order for a participant of the joint family farm venture to claim an agricultural-homestead classification; and (2) because the family farm corporation, not the joint family farm venture, owned the land in question, Frederick Farms was not entitled to claim an agricultural-homestead classification as a participant in a joint family farm venture. View "Frederick Farms, Inc. v. County of Olmsted" on Justia Law

The Railroad Revitalization and Regulatory Reform Act prevents states and their subdivisions from imposing discriminatory taxes against railroads. 49 U.S.C. 11501. In 2008, the drainage district, a subdivision of Illinois, changed its method for calculating assessments. All other owners are assessed on a per-acre formula, but railroad, pipeline, and utility land were to be assessed on the basis of "benefit," apparently based on the difference in value between land within the district and land outside the levees; annual crop rentals being paid; and agricultural production of lands within the district. Two rail carriers brought suit under a section of the Act, which prevents imposition of "another tax that discriminates against a rail carrier." The district court held that the assessment was prohibited by the Act, but concluded that it was powerless to enjoin the tax. The Seventh Circuit reversed, holding that the court has authority to enjoin the tax, but, under principles of comity, should eliminate only the discriminatory aspects, not the entire scheme. The assessment is a tax that, raises general revenues; its ultimate use is for the whole district. It imposes a proportionately heavier tax on railroading than other activities. View "Kansas City S. Ry. v. Koeller" on Justia Law