Justia Agriculture Law Opinion Summaries

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 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

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