Justia Agriculture Law Opinion Summaries

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

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