Justia Agriculture Law Opinion SummariesArticles Posted in Supreme Court of Mississippi
Scruggs, et al. v. Farmland Mutual Insurance Co.
Almost two decades prior to this decision, the Mississippi Supreme Court handed down Farmland Mutual Insurance Co. v. Scruggs, 886 So. 2d 714 (Miss. 2004). In that opinion, the Court held that Farmland Mutual Insurance Co., the liability insurer for Mitchell Scruggs, Eddie Scruggs, Scruggs Farms & Supplies LLC, and Scruggs Farm Joint Venture (collectively, Scruggs), had no duty to defend Scruggs in a federal lawsuit by Monsanto Company. The reason no coverage applied was because Monsanto had alleged that Scruggs committed the intentional act of conversion by saving and using unlicensed seeds. Eight years later, a district court judge overturned a jury’s verdict that Scruggs had willfully violated Monsanto’s patents. Consequently, Scruggs was not liable for treble damages and attorney’s fees. Scruggs returned to state court in 2013. Citing Rule 60(b) of the Mississippi Rules of Civil Procedure, Scruggs asked the Lee County Circuit Court to reopen and vacate the final judgment entered in 2004 in favor of Farmland on the coverage issue. Scruggs asserted the Mississippi Supreme Court’s opinion had been erroneously decided based on facts that came to light in the federal case. The state court rejected the motion as untimely under Rule 60(b). Scruggs appealed. While Scruggs asserted the motion was timely, the Mississippi Supreme Court found the motion’s timing is irrelevant: Rule 60(b) was not a procedural vehicle for a trial court to overturn a mandate issued from the Mississippi Supreme Court. Because the trial court lacked jurisdiction to grant Scruggs’s request, the Supreme Court affirmed the circuit court’s denial of the motion. View "Scruggs, et al. v. Farmland Mutual Insurance Co." on Justia Law
Briggs v. Hughes
Will Hughes and Chad Penn were commercial farmers who leased farmland in Madison County, Mississippi. They began using propane cannons in the summer months to deter deer from eating their crops. Because of the intentionally loud noise these devices created, neighboring property owners sought to enjoin Hughes and Penn from using the cannons. But citing the Mississippi Right to Farm Act, the chancellor found the neighbors’ nuisance claim was barred. Undisputedly, Hughes’s and Penn’s farms had been in operation for many years before the nuisance action was filed. So the chancery court ruled Miss. Code Ann. Section 95-3-29(1) was an absolute defense and dismissed the neighbors’ nuisance action. On appeal, the neighboring property owners argued the chancery court misinterpreted the statute. In their view, the chancery court erred by looking to how long the farms had been in operation instead of how long the practice of propane cannons had been in place. But the Mississippi Supreme Court found their proposed view contradicted the statute’s plain language. "The one-year time limitation in Section 95-3-29(1) does not hinge on the existence of any specific agricultural practice. Instead, it is expressly based on the existence of the agricultural operation, which 'includes, without limitation, any facility or production site for the production and processing of crops . . . .'" Applying the plain language in Section 95-3-29(2)(a), the Supreme Court found the properties being farmed were without question agricultural operations. And the propane cannons were part of those operations, because they were part of the farms’ best agricultural-management practices. Since the farms had been in operation for more than one year, the chancellor was correct to apply Section 95-3-29(1)’s bar. View "Briggs v. Hughes" on Justia Law