Justia Agriculture Law Opinion Summaries

Richard Orr and Sheldon Cook had a partnership agreement to conduct a cow-calf operation. The parties sold the cows and calves in the spring of 2007. Cook received $230,935 from the sale. Orr sued Cook, disputing the reimbursement amount Cook owed him from the sale and for the cost of feeding and caring for the cows during the winter of 2007. The trial court awarded Orr $41,614. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court was not clearly erroneous in determining the value of the calves; (2) the trial court was not clearly erroneous in determining the amount of reimbursement Cook owed Orr for feed and veterinarian costs; and (3) the trial court did err in refusing to award Orr prejudgment interest because it was requested in a manner allowed by statute. View "Orr v. Cook" on Justia Law

Defendant Robert St. Onge, president and member of Winterwood, operated a composting facility at his farm that accepted solid waste and converted it into compost for sale. The Department of Environmental Protection filed a land use complaint against Winterwood related to the discharge of pollutants from its composting operation into a nearby brook. The court entered a contempt order that required Winterwood to cease the discharge of pollutants into state waters. On the Department's motion to enforce the contempt order, the court ordered that Winterwood was immediately prohibited from receiving any other composting material. Later, four different waste companies delivered waste to Winterwood for composting. The state filed a criminal complaint and summons, charging St. Onge as principal of Winterwood with contempt. In superior court, St. Onge signed a jury trial waiver. The court adjudicated St. Onge to be in contempt as a Class D crime and sentenced him to six months in jail. St. Onge appealed. The Supreme Court affirmed all aspects of the judgment with the exception of the Class D modification. Because an adjudication of contempt with punitive sanctions is not a Class D crime, the judgment was modified accordingly. View "State v. St. Onge" on Justia Law

Plaintiffs in this putative class action were buyers and processors of farm-raised crawfish who sought to recover their economic loss from a pesticide manufacturer under the Louisiana Products Liability Act, (LPLA), La. Rev. State. Ann. 9:2800.54. At issue was whether the district court properly granted summary judgment to the manufacturer because plaintiffs' economic loss was unaccompanied by damage to their own person or property. The court held that, although plaintiffs have submitted evidence suggesting that they worked closely with crawfish farmers, plaintiffs have not submitted any evidence suggesting that the pesticide actually harmed their crawfish. The court also held that there was no evidence that plaintiffs were deprived of an actual, legal right to buy crawfish from the crawfish farmers. The court further denied plaintiffs' request to certify their proposed question to the Louisiana Supreme Court. Accordingly, the court affirmed the district court's order of summary judgment. View "Wiltz v. Bayer CropScience, L.P., et al." on Justia Law

The Agricultural Marketing Agreement Act of 1937 (AMAA), enacted to stabilize prices for agricultural commodities, regulate “handlers,” defined as “processors, associations of producers, and others engaged in the handling” of covered agricultural commodities, 7 U.S.C. 608c(1). The California Raisin Marketing Order, promulgated under the AMAA, established a Raisin Administrative Committee, which recommends annual reserve pools of raisins not to be sold on the open domestic market and requires handlers to pay assessments to help cover administrative costs. The petitioners, raisin producers, refused to surrender requisite portions of raisins to the reserve. The USDA began administrative proceedings. An ALJ found that petitioners were handlers and had violated the AMAA and the Order, and rejected a takings defense. The district court entered summary judgment for the USDA. The Ninth Circuit affirmed. A unanimous Supreme Court reversed, holding that the Ninth Circuit had jurisdiction to decide the takings claim. Petitioners argued that they were producers, not subject to the AMAA or the Order, but the USDA and the district court concluded that they were handlers. Fines and penalties were levied on them in that capacity. Their takings claim, therefore, was necessarily raised in that capacity. The Ninth Circuit confused a statutory argument that they were producers with a constitutional argument that, if they were handlers, their fine violated the Fifth Amendment. The claim was ripe. The petitioners were subject to a final agency order; because the AMAA provides a comprehensive remedial scheme that withdraws Tucker Act jurisdiction over a handler’s takings claim, there is no alternative remedy. View "Horne v. Department of Agriculture" on Justia Law

Monsanto invented and patented Roundup Ready soybean seeds, which contain a genetic alteration that allows them to survive exposure to the herbicide glyphosate. It sells the seeds subject to a licensing agreement that permits farmers to plant the purchased seed in only one growing season. Growers may consume or sell the resulting crops, but may not save any of the harvested soybeans for replanting. Bowman purchased Roundup Ready soybean seed for his first crop of each growing season. To reduce costs for his riskier late-season planting, Bowman purchased soybeans intended for consumption; planted them; treated the plants with glyphosate, killing all plants without the Roundup Ready trait; harvested the resulting soybeans that contained that trait; and saved some of these harvested seeds to use in his late-season planting the next season. After discovering this practice, Monsanto sued for patent infringement. Bowman raised the defense of patent exhaustion, which gives the purchaser of a patented article, or any subsequent owner, the right to use or resell that article. The district court rejected Bowman’s defense; the Federal Circuit affirmed. In a unanimous decision, the Supreme Court affirmed. Patent exhaustion does not permit a farmer to reproduce patented seeds through planting and harvesting without permission. Under the patent exhaustion doctrine, the initial authorized sale terminates all patent rights to the patented item and confers on the purchaser, or any subsequent owner, the right to use or sell the thing, but the doctrine restricts the patentee’s rights only as to the “particular article” sold. It leaves untouched the patentee’s ability to prevent a buyer from making new copies. By planting and harvesting patented seeds, Bowman made additional copies of Monsanto’s patented invention, which falls outside the protections of patent exhaustion. If Bowman were granted an exception, patents on seeds would retain little value. View "Bowman v. Monsanto Co." on Justia Law

Petitioner, a trade association representing meatpackers and processors, sued to enjoin enforcement of a California law against swine slaughterhouses, arguing that the Federal Meat Inspection Act (FMIA), 21 U.S.C. 601, et seq., preempted application of the law. The California law dictated what slaughterhouses must do with pigs that could not walk, known in the trade as nonambulatory pigs. The Court concluded that the FMIA regulated slaughterhouses' handling and treatment of nonambulatory pigs from the moment of their delivery through the end of the meat production process. California's law endeavored to regulate the same thing, at the same time, in the same place - except by imposing different requirements. The FMIA expressly preempted such a state law. Accordingly, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings. View "National Meat Assn. v. Harris" on Justia Law

The Agricultural Marketing Agreement Act of 1937 (AMAA), enacted to stabilize prices for agricultural commodities, regulate “handlers,” defined as “processors, associations of producers, and others engaged in the handling” of covered agricultural commodities, 7 U.S.C. 608c(1). The California Raisin Marketing Order, promulgated under the AMAA, established a Raisin Administrative Committee, which recommends annual reserve pools of raisins not to be sold on the open domestic market and requires handlers to pay assessments to help cover administrative costs. The petitioners, raisin producers, refused to surrender requisite portions of raisins to the reserve. The USDA began administrative proceedings. An ALJ found that petitioners were handlers and had violated the AMAA and the Order, and rejected a takings defense. The district court entered summary judgment for the USDA. The Ninth Circuit affirmed. A unanimous Supreme Court reversed, holding that the Ninth Circuit had jurisdiction to decide the takings claim. Petitioners argued that they were producers, not subject to the AMAA or the Order, but the USDA and the district court concluded that they were handlers. Fines and penalties were levied on them in that capacity. Their takings claim, therefore, was necessarily raised in that capacity. The Ninth Circuit confused a statutory argument that they were producers with a constitutional argument that, if they were handlers, their fine violated the Fifth Amendment. The claim was ripe. The petitioners were subject to a final agency order; because the AMAA provides a comprehensive remedial scheme that withdraws Tucker Act jurisdiction over a handler’s takings claim, there is no alternative remedy. View "Horne v. Department of Agriculture" on Justia Law

Monsanto invented and patented Roundup Ready soybean seeds, which contain a genetic alteration that allows them to survive exposure to the herbicide glyphosate. It sells the seeds subject to a licensing agreement that permits farmers to plant the purchased seed in only one growing season. Growers may consume or sell the resulting crops, but may not save any of the harvested soybeans for replanting. Bowman purchased Roundup Ready soybean seed for his first crop of each growing season. To reduce costs for his riskier late-season planting, Bowman purchased soybeans intended for consumption; planted them; treated the plants with glyphosate, killing all plants without the Roundup Ready trait; harvested the resulting soybeans that contained that trait; and saved some of these harvested seeds to use in his late-season planting the next season. After discovering this practice, Monsanto sued for patent infringement. Bowman raised the defense of patent exhaustion, which gives the purchaser of a patented article, or any subsequent owner, the right to use or resell that article. The district court rejected Bowman’s defense; the Federal Circuit affirmed. In a unanimous decision, the Supreme Court affirmed. Patent exhaustion does not permit a farmer to reproduce patented seeds through planting and harvesting without permission. Under the patent exhaustion doctrine, the initial authorized sale terminates all patent rights to the patented item and confers on the purchaser, or any subsequent owner, the right to use or sell the thing, but the doctrine restricts the patentee’s rights only as to the “particular article” sold. It leaves untouched the patentee’s ability to prevent a buyer from making new copies. By planting and harvesting patented seeds, Bowman made additional copies of Monsanto’s patented invention, which falls outside the protections of patent exhaustion. If Bowman were granted an exception, patents on seeds would retain little value. View "Bowman v. Monsanto Co." on Justia Law

Petitioner, a trade association representing meatpackers and processors, sued to enjoin enforcement of a California law against swine slaughterhouses, arguing that the Federal Meat Inspection Act (FMIA), 21 U.S.C. 601, et seq., preempted application of the law. The California law dictated what slaughterhouses must do with pigs that could not walk, known in the trade as nonambulatory pigs. The Court concluded that the FMIA regulated slaughterhouses' handling and treatment of nonambulatory pigs from the moment of their delivery through the end of the meat production process. California's law endeavored to regulate the same thing, at the same time, in the same place - except by imposing different requirements. The FMIA expressly preempted such a state law. Accordingly, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings. View "National Meat Assn. v. Harris" on Justia Law

Petitioner, a trade association representing meatpackers and processors, sued to enjoin enforcement of a California law against swine slaughterhouses, arguing that the Federal Meat Inspection Act (FMIA), 21 U.S.C. 601, et seq., preempted application of the law. The California law dictated what slaughterhouses must do with pigs that could not walk, known in the trade as nonambulatory pigs. The Court concluded that the FMIA regulated slaughterhouses' handling and treatment of nonambulatory pigs from the moment of their delivery through the end of the meat production process. California's law endeavored to regulate the same thing, at the same time, in the same place - except by imposing different requirements. The FMIA expressly preempted such a state law. Accordingly, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings. View "National Meat Assn. v. Harris" on Justia Law