Justia Agriculture Law Opinion Summaries

A nuisance lawsuit was brought by neighbors against two poultry farms located on a single tract of rural land in Henderson County, southeast of Dallas. The neighbors claimed that the odors from the farms were a nuisance, causing them discomfort and annoyance. A jury found that the odors were a temporary nuisance and the trial court granted permanent injunctive relief that effectively shut down the farms. The farm owners and operators appealed, challenging the injunction on three grounds: whether the trial court abused its discretion in finding imminent harm; whether equitable relief was unavailable because damages provide an adequate remedy; and whether the scope of the injunction is overly broad.The Supreme Court of Texas upheld the trial court’s authority to grant an injunction, rejecting the first two challenges. However, the court concluded that the trial court abused its discretion in crafting the scope of the injunction, which was broader than necessary to abate the nuisance. The court therefore reversed in part and remanded for the trial court to modify the scope of injunctive relief. View "HUYNH v. BLANCHARD" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing the order of the district court granting summary judgment for Helena Chemical Company in this action brought by Plaintiffs claiming that an aerial herbicide drifted onto their farms and damaged their cotton crops, holding that the district court did not err in granting summary judgment for Helena.Plaintiffs sued Defendant, which oversaw the aerial application of herbicide that Plaintiffs alleged Defendants were responsible for reducing crop yields in over 14,000 acres of cotton fields, seeking recovery under various theories, as well as mental anguish damages and punitive damages. The district court granted summary judgment in favor of Helena. The court of appeals reversed in large part. The Supreme Court reversed in part and reinstated the summary judgment for Helena, holding that the evidence presented by Plaintiffs that Helena's application of the herbicide caused Plaintiffs' injury did not raise a genuine issue of material fact required to survive summary judgment. View "Helena Chemical Co. v. Cox" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that the Texas Farm Animal Activity Act (the Act), Tex. Civ. Proc. & Rem. Code 87.001-87.005, does not apply to ranchers and ranch hands, holding that the court of appeals did not err.The Act limits liability for injury to "a participant in a farm animal activity or livestock show" that results from an "inherent risk" of those activities. Raul Zuniga worked full-time for Conway and Marlene Waak to work cattle on a ranch, landscape, and cut hay. Zuniga died after being trampled. Plaintiffs, Zuniga's family, sued the Waaks, on wrongful death and survival claims. The trial court granted summary judgment for the Waaks, concluding that the Act barred Plaintiffs' claims. The court of appeals reversed, concluding that Zuniga was not "a participant in a farm animal activity" for whose injuries and death the Act limits liability. The Supreme Court affirmed, holding that the Act does not cover ranchers and ranch hands and, therefore, did not shield the Waaks from liability for their negligence resulting in Zuniga's death. View "Waak v. Rodriguez" on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals applying Tex. Agric. Code 143.074 in holding that Plaintiff, the driver on a state highway that collided with an escaped bull in a county with a stock law, could recover against Defendant, the livestock owner, without showing the livestock owner knowingly permitted the bull to roam at large, holding that the court of appeals erred.Specifically, the Supreme Court held (1) when cars collide with livestock on state highways in counties with stock laws, the differing standards of livestock-owner liability imposed by section 143.102 and section 143.074 cannot both apply; (2) section 143.102 provided the exclusive standard for the livestock owner's liability because the accident occurred on a state highway; and (3) because the plaintiff could not demonstrate the defendant violated section 143.102's liability standard, summary judgment was properly granted for the defendant on all claims. View "Pruski v. Garcia" on Justia Law