Justia Agriculture Law Opinion Summaries

Purchasers of egg products accused suppliers of conspiring to reduce the supply of eggs and increase the price for egg products in violation of the Sherman Act, 15 U.S.C. 1. Plaintiffs alleged that the producers conspired to reduce the population of egg-laying hens, resulting in a reduced supply of eggs and, given the inelasticity of demand, supra-competitive prices. A trade association coordinated a certification program under which participants had to increase their cage sizes and not replace hens that died. Plaintiffs alleged that the proffered animal welfare rationale was a pretext to reduce supply. The district court, citing a bar on indirect purchaser actions, concluded that the purchaser-plaintiffs lacked standing. The Third Circuit reversed. As a matter of first impression, a direct purchaser of a product that includes a price-fixed input has antitrust standing to pursue a claim against the party that sold the product to the purchaser, where the seller is a participant in the price-fixing conspiracy, but the product also includes some price-fixed input supplied by a third-party non-conspirator. The direct relationship between the purchasers and their suppliers and the fact that the suppliers are alleged price-fixing conspirators, not merely competitors of those conspirators, are key factors. Regardless of who collected the overcharge, the purchasers’ econometric analysis purports to show the “difference between the actual [supracompetitive] price and the presumed competitive price” of the egg products they purchased. This purported difference, and the purchasers’ resulting injury, was allegedly a direct and intended result of the suppliers’ conspiracy. View "In Re: Processed Egg Products Antitrust Litigation" on Justia Law

Purchasers of egg products accused suppliers of conspiring to reduce the supply of eggs and increase the price for egg products in violation of the Sherman Act, 15 U.S.C. 1. Plaintiffs alleged that the producers conspired to reduce the population of egg-laying hens, resulting in a reduced supply of eggs and, given the inelasticity of demand, supra-competitive prices. A trade association coordinated a certification program under which participants had to increase their cage sizes and not replace hens that died. Plaintiffs alleged that the proffered animal welfare rationale was a pretext to reduce supply. The district court, citing a bar on indirect purchaser actions, concluded that the purchaser-plaintiffs lacked standing. The Third Circuit reversed. As a matter of first impression, a direct purchaser of a product that includes a price-fixed input has antitrust standing to pursue a claim against the party that sold the product to the purchaser, where the seller is a participant in the price-fixing conspiracy, but the product also includes some price-fixed input supplied by a third-party non-conspirator. The direct relationship between the purchasers and their suppliers and the fact that the suppliers are alleged price-fixing conspirators, not merely competitors of those conspirators, are key factors. Regardless of who collected the overcharge, the purchasers’ econometric analysis purports to show the “difference between the actual [supracompetitive] price and the presumed competitive price” of the egg products they purchased. This purported difference, and the purchasers’ resulting injury, was allegedly a direct and intended result of the suppliers’ conspiracy. View "In Re: Processed Egg Products Antitrust Litigation" on Justia Law

Plainitffs appealed when their claims against a person who sold a steer for slaughter were dismissed. The steer was later found to be contaminated with E. coli bacteria. Patty Anderson agreed to sell a 4-H steer for her eighteen-year-old granddaughter. Joseph Deiter purchased one-half of the steer. Anderson contacted Donald Janak, who owned a mobile slaughtering business. He was asked to slaughter the steer for Deiter, and to deliver the carcass to Don’s Meats, which was a custom meat processing business that was owned and operated by Donald and Sharon Coons and their daughter Penny Coons. Janak slaughtered and skinned the steer, cut the carcass in half down the middle, and delivered the two halves of the carcass to Don’s Meats, where the meat was processed. After eating the meat, the members of the Deiter family became ill due to becoming infected with E. coli bacteria. The Deiters filed suit against Anderson, Janak and his corporation, and the Coonses. Anderson successfully moved for summary judgment as to the claims against her. The Coonses also successfully moved for summary judgment. The Deiters settled with Janak, and they appealed the judgment in favor of Anderson and the Coonses. The Deiters argued to the district court that Anderson and the Coonses violated the Federal Meat Inspection Act because she sold or offered for sale, in commerce, articles which were capable for use as human food and which were adulterated at the time of the sale or offer for sale as proscribed by 21 U.S.C. 610(c). Finding that the Deiters did not show any genuine issue of material fact with respect to the grant of summary judgment to Anderson or the Coonses, the Supreme Court affirmed dismissal of claims against those parties. View "Deiter v. Coons" on Justia Law

The issue this case presented for the Supreme Court's review was a contract dispute between Silver Creek Seed, LLC and Sunrain Varieties, LLC, arising from the development of Bacterial Ring Rot (“BRR”) in two of the potato varieties grown by Silver Creek for Sunrain. After a four-day trial, the jury returned a verdict awarding damages to Silver Creek. Sunrain appealed: (1) the district court’s denial of a motion to reconsider an order granting partial summary judgment to Silver Creek; (2) the exclusion of the back side of the Idaho Crop Improvement Association (“ICIA”) blue tag from evidence; (3) the admission of testimony relating to the source of the BRR; (4) alleged errors in jury instructions; (5) the award of prejudgment interest to Silver Creek and (6) the award of attorney fees and costs to Silver Creek. Finding no reversible error, the Supreme Court affirmed. View "Silver Creek Seed v. Sunrain Varieties" on Justia Law

A federal district court certified two questions of law to the Iowa Supreme Court in a priority dispute between competing creditors of a bankrupt hog operation. Crooked Creek Corporation operated a farrow-to-finish hog facility where it bred gilts and sows and raised their litters for slaughter. After the company filed for bankruptcy, the hogs were sold, but the sale did not generate enough money to pay off competing liens asserted by two of Crooked Creek’s creditors: Oyens Feed & Supply, Inc. and Primebank. Oyens Feed held an agricultural supply dealer lien because it sold Crooked Creek feed “on credit . . . to fatten the hogs to market weight.” Primebank had a perfected article 9 security interest in the hogs to secure two promissory notes predating Oyens Feed’s section 570A.5(3) agricultural supply dealer lien in the hogs. At trial, Oyens Feed claimed it was entitled to all of the escrowed funds because its agricultural supply dealer lien had superpriority over Primebank’s earlier perfected security interest. The bankruptcy court concluded the plain meaning of section 570A.4 created a “discrete window of time,” beginning with the farmer’s purchase of feed and ending thirty-one days later, within which an agricultural supply dealer must file a financing statement to perfect its lien. The bankruptcy court concluded Oyens Feed had only perfected its lien as to amounts for feed delivered in the thirty-one days preceding the filing of each of its financing statements. In reaching its decision on the extent of Oyens Feed’s lien in the escrowed funds, the bankruptcy court reasoned the acquisition price of the hogs was zero because Crooked Creek raised hogs from birth rather than purchasing them. The court concluded “the ‘purchase price’ comprises the vast majority, if not all of, the ‘acquisition price’ for . . . purposes of Iowa Code § 570A.5(3).” The United States District Court for the Northern District of Iowa asked the Iowa Supreme Court: (1) whether, pursuant to Iowa Code section 570A.4(2), was an agricultural supply dealer required to file a new financing statement every thirty-one (31) days in order to maintain perfection of its agricultural supply dealer’s lien as to feed supplied within the preceding thirty-one (31) day period?; and (2) whether pursuant to Iowa Code section 570A.5(3), was the “acquisition price” zero when the livestock are born in the farmer’s facility? The Supreme Court answered both certified questions in the affirmative. View "Oyens Feed & Supply, Inc. v. Primebank" on Justia Law

Plaintiff Duarte Nursery, Inc. sold grape rootstock. It challenged mandatory assessments it had to pay to the California Grape Rootstock Improvement Commission to help fund research for pest-resistant and drought-resistant rootstock, arguing this “Commission Law” and the Commission’s operation as an unconstitutional exercise of the state’s police power in violation of plaintiff’s liberty interests and due process rights under the federal and state Constitutions. In this appeal, instead of claiming impairment of its rights to free speech or free association, plaintiff asserted a right to refuse to help fund research that benefitted the industry as a whole. Plaintiff sought injunctive and declaratory relief and refunds. After a bench trial, the trial court entered judgment in favor of defendants, the Commission and the Secretary of the California Department of Food and Agriculture (Secretary). Finding no reversible error, the Court of Appeal affirmed. View "Duarte Nursery v. Cal. Grape Rootstock Improvement Comm." on Justia Law

During the 1970s and 1980s, American Agri‐Corp organized several limited partnerships, for which the company served as general partner. American solicited high‐income individuals to serve as limited partners, investing in supposed agricultural ventures. According to the IRS, the actual purpose was to shelter the income of limited partners from taxation. Plaintiffs were each limited partners (or spouses) in at least one partnership that was audited by the IRS during the mid‐1980s. Several years later, the IRS concluded that the partnerships were, essentially, tax‐avoidance schemes .In 1990 and 1991, the IRS issued Final Partnership Administrative Adjusts for the partnerships and disallowed several listed farming expenses and other deductions for the 1984 or 1985 tax years. The Tax Court consolidated cases, held that the IRS action was not time‐barred, and determined that the partnerships had engaged in “transactions which lacked economic substance” that resulted in a substantial distortion of income and expense. The district court held that it lacked subject‐matter jurisdiction over the taxpayers’ claims that the assessments were untimely and improperly included penalty interest. The Seventh Circuit affirmed. The determinations at issue are attributable to partnership items over which courts lack subject‐matter jurisdiction. View "Acute Care Specialists II v. United States" on Justia Law

The Scotts Company, an Ohio LLC, brought a diversity action against Seeds, Inc., a Washington corporation, in federal district court. Thereafter, Millhorn Farmers, Maple Leaf Farms, Mica Creek, and Tim Freeburg (Growers) sued Seeds and Scotts in Washington state court. Maple Leaf Farms and Mica Creek were Washington corporations, Millhorn Farms was an Idaho corporation, and Tim Freeburg was a citizen of Idaho. Scotts subsequently filed an amended complaint in federal court adding the Growers as defendants and seeking declaratory relief. The district court subsequently realigned the Growers and plaintiffs and Seeds and Scotts as defendants and held, alternatively, that it would stay the federal proceedings in favor of the related state court proceedings under either the Brillhart doctrine or the Colorado River doctrine. Because the parties' realignment resulted in the absence of complete diversity of citizenship between defendant Seeds and newly-aligned plaintiffs-Growers, the district court dismissed the action for lack of subject matter jurisdiction. The Ninth Circuit Court of Appeals reversed, holding that the district court should not have declined to entertain the claim for declaratory relief under the Brillhart doctrine, and instead, the claims should have been evaluated under the Colorado River doctrine. Remanded. View "Scotts Co., LLC v. Seeds, Inc." 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

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