Justia Agriculture Law Opinion Summaries

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

The Railroad Revitalization and Regulatory Reform Act prevents states and their subdivisions from imposing discriminatory taxes against railroads. 49 U.S.C. 11501. In 2008, the drainage district, a subdivision of Illinois, changed its method for calculating assessments. All other owners are assessed on a per-acre formula, but railroad, pipeline, and utility land were to be assessed on the basis of "benefit," apparently based on the difference in value between land within the district and land outside the levees; annual crop rentals being paid; and agricultural production of lands within the district. Two rail carriers brought suit under a section of the Act, which prevents imposition of "another tax that discriminates against a rail carrier." The district court held that the assessment was prohibited by the Act, but concluded that it was powerless to enjoin the tax. The Seventh Circuit reversed, holding that the court has authority to enjoin the tax, but, under principles of comity, should eliminate only the discriminatory aspects, not the entire scheme. The assessment is a tax that, raises general revenues; its ultimate use is for the whole district. It imposes a proportionately heavier tax on railroading than other activities. View "Kansas City S. Ry. v. Koeller" on Justia Law

Plaintiffs, raisin producers, appealed an administrative decision by the United States Department of Agriculture (USDA), which imposed civil penalties and assessments for their failure to comply with the reserve pool requirements for raisins, among other regulatory infractions. At issue was the interpretation and constitutionality of a food product reserve program authorized by the Agricultural Marketing Agreement Act of 1937 (AMAA), 7 U.S.C. 601 et seq., and implemented by the Marketing Order Regulating the Handling of Raisins Produced from Grapes Grown in California (Marketing Order), 7 C.F.R. Part 989, first adopted in 1949, which contained the reserve pool requirements. The court held that applying the Marketing Order to plaintiffs in their capacity as handlers was not contrary to the AMAA. The court also held that plaintiffs have suffered no compensable physical taking of any portion of their crops and therefore, the Fifth Amendment posed no obstacle to the enforcement of the Marketing Order under the Takings Clause. The court further held that the district court did not err in finding that the penalties were consistent with the Eighth Amendment and were not excessive fines. Accordingly, the court affirmed the judgment. View "Horne, et al. v. US Dept. of Agriculture" on Justia Law

Petitioners sought administrative review of the Chief of the Perishable Agricultural Commodities Act ("PACA"), 7 U.S.C. 499, and Vegetable Division of the Agricultural Marketing Service's ("Judicial Officer") determination that petitioners, who were officers of national produce wholesalers, Fresh America, had been responsibly connected to Fresh America during the violations period at issue and were subject to the statute's employment restrictions. At issue was whether petitioners were merely nominal officers to Fresh America and whether Fresh America was the alter ego of its chairman of the board. The court granted the petition for review where the Judicial Officer's decision was devoid of any analysis of the actual power exercised by petitioners at Fresh America. The court also held that Fresh America was dominated by the board and its chairman, not just by the chairman. View "Cheryl Taylor, et al v. US Department of Agriculture, et al" on Justia Law