Justia Agriculture Law Opinion Summaries

The case involves M&T Farms, a California general partnership between two farmers, who purchased crop insurance under the Whole-Farm Revenue Protection Pilot Policy (the “WFRP Policy”) from Producers Agriculture Insurance Company (“ProAg”), an insurer approved and reinsured by the Federal Crop Insurance Corporation (FCIC). M&T Farms and a third farmer sell farm commodities through a storefront, B&T Farms, which owns their business name and goodwill and is also a California general partnership. M&T Farms filed a claim seeking the full policy amount, which ProAg denied. The FCIC concluded that the WFRP Policy does not allow a partner who files taxes on a fractional share of farming activity conducted by a partnership to be eligible for WFRP coverage for the fractional share of that farming activity.The United States District Court for the Northern District of California granted summary judgment in favor of the FCIC. M&T Farms challenged the FCIC’s decision that a partnership “holding the business name and good will of [others] (i.e., marketing and selling the commodities produced)” is engaged in “farming activity” under section 3(a)(4) of the WFRP Policy, and that therefore, any entity reporting a fractional share of the partnership’s activity on its tax returns is ineligible for WFRP Policy coverage.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The court held that the WFRP Policy contained an ambiguity regarding the definition of “farming activity.” The FCIC’s conclusion that a partnership selling its partners’ products and holding their goodwill and business name was engaged in “farming activity” under section 3(a)(4) of the policy had a reasonable basis and was also reasonable as a matter of policy. Because the FCIC’s interpretation of “farming activity” in the WFRP Policy was reasonable, it survived APA arbitrary and capricious review. The court also held that the term “farming activity” in the WFRP policy was genuinely ambiguous, the FCIC’s conclusion had a reasonable basis, and the FCIC’s conclusion was entitled to controlling weight. View "M & T FARMS V. FEDERAL CROP INSURANCE CORPORATION" on Justia Law

James and Levi Garrett, a father and son farming duo in South Dakota, were found guilty by a jury of making false statements in connection with federal crop insurance. The Garretts had participated in a federal crop insurance program, administrated by Crop Risk Services (CRS) and backed by the Risk Management Agency of the United States Department of Agriculture (USDA). They had obtained insurance for sunflower crops in 2018, and James had obtained insurance for a corn crop in 2019. The Garretts were accused of falsely certifying the number of acres of sunflowers and corn they planted in 2018 and 2019 respectively, and subsequently reporting harvest losses to CRS.The case went to trial in October 2022. The jury heard from several witnesses and examined dozens of exhibits. At the conclusion of the trial, James was convicted on two counts of making a false statement in connection with insurance for sunflower and corn crops, and Levi was convicted on one count of making a false statement in connection with insurance for a sunflower crop. The Garretts moved for judgment of acquittal, and in the alternative, a new trial, arguing there was insufficient evidence to support their convictions. The district court denied their motion.The Garretts appealed to the United States Court of Appeals for the Eighth Circuit, challenging the district court’s evidentiary rulings and its denial of their post-trial motions. They argued that the district court erred in admitting certain evidence and excluding others, and that there was insufficient evidence to support their convictions. The Court of Appeals affirmed the judgment of the district court, concluding that the trial record supported the jury verdict and that the district court did not err in its evidentiary rulings or in denying the Garretts' post-trial motions. View "United States v. Garrett" on Justia Law

This case involves a dispute between a grain producer, Robert Miller, and the Illinois Department of Agriculture over compensation from the Illinois Grain Insurance Fund. The fund is intended to compensate grain producers for losses incurred when a licensed grain dealer or a licensed warehouseman fails. Miller made a claim with the Department after his grain dealer, SGI Agri-Marketing, LLC, failed before making payment under a “price later contract.”A key issue in the case was the interpretation of the Grain Code's provision concerning the pricing of grain under a “price later contract.” According to the Code, if such a contract is not signed by all parties within 30 days of the last date of delivery of grain intended to be sold by the contract, then the grain is automatically priced on the next business day after those 30 days, at the market price of the grain at the close of that day.Miller argued that the grain was priced when he signed a purchase confirmation, which was within the 160-day window before the failure of the dealer, thus entitling him to compensation from the fund. The Department contended that the Grain Code automatically priced the grain as a matter of law on the next business day after 30 days from the last grain delivery, as the parties had not signed a contract agreeing to a pricing formula by then.The Supreme Court of the State of Illinois agreed with the Department’s interpretation. It held that the statute was unambiguous and provided that the grain would be priced as a matter of law on the next business day after 30 days from the last delivery. Therefore, because the grain was priced outside the 160-day protection window prescribed by the Grain Code, Miller was not eligible for compensation from the fund. The Supreme Court affirmed the circuit court’s judgment and reversed the appellate court's judgment. View "Miller v. Department of Agriculture" on Justia Law

In the case, Mojave Pistachios, LLC (Mojave) and other petitioners sought to challenge a replenishment fee on groundwater extractions imposed by the Indian Wells Valley Groundwater Authority (the Authority) in California. Mojave, which owns approximately 1,600 acres of land in the Mojave Desert, uses groundwater to irrigate its pistachio orchard. The Authority, created under the Sustainable Groundwater Management Act (SGMA), determined that all groundwater extractions in the water basin where Mojave’s orchard is located would be subject to a replenishment fee, which Mojave refused to pay. The Superior Court of Orange County sustained the Authority’s demurrer to certain causes of action in Mojave's third amended complaint, finding the claims were barred by California’s “pay first, litigate later” rule which requires a taxpayer to pay a tax before commencing a court action to challenge the tax’s collection.Mojave petitioned the Court of Appeal of the State of California Fourth Appellate District Division Three for a writ of mandate overruling the lower court's order. The appellate court concluded that the well-established “pay first” rule applies to lawsuits challenging fees imposed by a local groundwater sustainability agency under SGMA. As such, because any alleged economic harm to Mojave stems from the imposition of the replenishment fee, the “pay first” rule bars the challenged causes of action. The appellate court affirmed the lower court's decision and denied Mojave's petition for a writ of mandate. View "Mojave Pistachios, LLC v. Superior Court" on Justia Law

The Supreme Court affirmed the decision of the district court entering summary judgment for the United States and rejecting the lawsuit brought by Appellant asking the district court to overturn the finding of the Food and Nutrition Service (FNS) of the United States Department of Agriculture that Appellant was disqualified from further participation in the supplemental nutrition assistance program (SNAP), holding that there was no error.FNS disqualified Appellant from further participation in SNAP after investigating evidence of unlawful trafficking in SNAP benefits. Thereafter, Appellant brought this action seeking to overturn the FNS's liability finding and asking the court to vacate the order of program disqualification as arbitrary and capricious. The district court entered summary judgment for the United States. The Supreme Court affirmed, holding (1) the district court did not err in entering summary judgment in favor of the United States on the liability issue; and (2) the sanction of the permanent disqualification order from the program was neither arbitrary nor capricious. View "AJ Mini Market, Inc. v. United States" on Justia Law

California’s Proposition 12 forbids the in-state sale of whole pork meat that comes from breeding pigs (or their immediate offspring) that are “confined in a cruel manner.” Confinement is “cruel” if it prevents a pig from “lying down, standing up, fully extending [its] limbs, or turning around freely.” Opponents alleged that Proposition 12 violated the Constitution by impermissibly burdening interstate commerce, arguing that the cost of compliance with Proposition 12 will increase production costs and, because California imports almost all the pork it consumes, most of Proposition 12’s compliance costs will be borne by out-of-state firms.The Ninth Circuit and Supreme Court affirmed the dismissal of the case, rejecting arguments under the dormant Commerce Clause. Absent purposeful discrimination, a state may exclude from its territory, or prohibit the sale therein of any articles which, in its judgment, fairly exercised, are prejudicial to the interests of its citizens. Proposition 12 imposes the same burdens on in-state pork producers that it imposes on out-of-state pork producers. Proposition 12 does not implicate the antidiscrimination principle.The Court rejected an argument that its precedents include an “almost per se” rule forbidding enforcement of state laws that have the practical effect of controlling commerce outside the state, even when those laws do not purposely discriminate against out-of-state interests. While leaving the courtroom door open to challenges premised on even nondiscriminatory burdens, the Court noted that “extreme caution is warranted.” View "National Pork Producers Council v. Ross" on Justia Law

Some of the practices that have made California's Central Valley an "agricultural powerhouse" have also adversely impacted the region’s water quality and environmental health. Respondents State Water Resources Control Board (State Water Board) and Central Valley Regional Water Quality Control Board (Central Valley Water Board) are responsible for regulating waste discharges from irrigated agricultural operations in the Central Valley. The State Water Board adopted order WQ 2018-0002 (Order) in February 2018. Environmental Law Foundation (Foundation), Monterey Coastkeeper (Coastkeeper), and Protectores del Agua Subterranea (Protectores) (collectively, appellants) brought petitions for writs of mandate challenging various aspects of the Order. The trial court consolidated the cases and granted a motion for leave to intervene by the East San Joaquin Water Quality Coalition (Coalition) and others (cumulatively, the Coalition). Following a hearing on the merits, the trial court denied the petitions. Appellants appealed, advancing numerous claims of error. Ultimately, the Court of Appeal rejected these arguments and affirmed the judgments. View "Environmental Law Foundation v. State Water Resources Control Bd." on Justia Law

Bachman Farms grows apples in Ohio and protected its 2017 crop with federally reinsured crop insurance from Producers Agriculture. When farmers and private insurers enter a federally reinsured crop insurance contract, they agree to common terms set by the Federal Crop Insurance Corporation (FCIC), including a requirement that the parties arbitrate coverage disputes. In those proceedings, the arbitrator must defer to agency interpretations of the common policy. Failure to do so results in the nullification of the arbitration award. Bachman lost at its arbitration with Producers Agriculture and alleged that the arbitrator engaged in impermissible policy interpretation. Bachman petitioned to nullify the arbitration award.The Sixth Circuit affirmed the dismissal of the suit. The petition to nullify did not comply with the substance or the three-month time limit of the Federal Arbitration Act (FAA), 9 U.S.C. 12. When a dispute concerning federally reinsured crop insurance involves a policy or procedure interpretation, the parties “must obtain an interpretation from FCIC.” Bachman did not seek an interpretation from FCIC but went directly to federal court to seek nullification under the common policy and its accompanying regulations—an administrative remedy—rather than vacatur under the FAA. View "Bachman Sunny Hill Fruit Farms v. Producers Agriculture Insurance Co." on Justia Law

=Public Water Supply District No. 1 of Greene County, Missouri (“PWSD”) and the City of Springfield, Missouri (the “City”) filed cross motions for summary judgment, and the district court1 granted summary judgment in favor of the City. The district court also denied PWSD’s subsequent motion to alter or amend the judgment under Rule 59(e) of the Federal Rules of Civil Procedure. PWSD appealed these decisions. PWSD asserts its claims are timely under the continuing-violations doctrine because the City continues to provide water to customers within the Disputed Subdivisions.   The Eighth Circuit affirmed the finding that PWSD’s claims are time-barred. Here, it is undisputed that the City began serving each of the Disputed Subdivisions in or before 1994. Based on the principles set forth above, a § 1926(b) violation must occur (and the statute of limitations accrues) when a municipality begins providing service to a new subdivision, and “not when it continues to do so.” Contrary to PWSD’s contention, it is not a continuing violation, and the statute of limitations does not reset when a municipality continues to add and provide service to customers in a subdivision it already serves. View "Public Water Supply District No. 1 of Greene Co v. City of Springfield, Missouri" on Justia Law

A nonprofit entity representing commercial fishers sued the Alaska Board of Fisheries and the Department of Fish and Game, alleging that the State’s fishery management practices in Cook Inlet were unjustified and violated federal law and national standards. The nonprofit sought to depose two current Fish and Game employees but the State opposed, arguing that all material facts necessary for a decision of the case were in the administrative record. The superior court agreed with the State and quashed the nonprofit’s deposition notices. The court also granted summary judgment in favor of the State, deciding that the Cook Inlet fishery was not governed by federal standards and that none of the nonprofit’s disagreements with the State’s fishery management practices stated a violation of statute or regulation. The nonprofit appealed. Finding no reversible error, the Alaska Supreme Court affirmed the superior court judgment. View "Cook Inlet Fisherman’s Fund v. Alaska Dept. of Fish & Game, et al." on Justia Law