Justia Agriculture Law Opinion Summaries

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Jeff Good and Harry’s Dairy entered into a contract providing that Harry’s Dairy would purchase 3,000 tons of Good’s hay. Harry’s Dairy paid for and hauled approximately 1,000 tons of hay over a period of approximately eight weeks, but did not always pay for the hay before hauling it and at one point went several weeks without hauling hay. After Harry’s Dairy went a month without hauling additional hay, Good demanded that Harry’s Dairy begin paying for and hauling the remaining hay. Harry’s Dairy responded that it had encountered mold in some of the hay, but would be willing to pay for and haul non-moldy hay at the contract price. Good then sold the remaining hay for a substantially lower price than he would have received under the contract and filed a complaint against Harry’s Dairy alleging breach of contract. Harry’s Dairy counterclaimed for violation of implied and express warranties and breach of contract. The district court granted summary judgment in favor of Good on all claims, and a jury ultimately awarded Good $144,000 in damages. Harry’s Dairy appealed, arguing that there were several genuine issues of material fact precluding summary judgment, that the jury verdict was not supported by substantial and competent evidence, and that the district court erred in awarding attorney fees, costs, and prejudgment interest to Good. Finding only that the district court erred in granting summary judgment on the implied warranty of merchantability counterclaim, the Idaho Supreme Court reversed as to that issue, affirmed as to all others, and remanded for further proceedings. View "Good v. Harry's Dairy" on Justia Law

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Plaintiffs filed suit against the United States and others, alleging violations of the Federal Tort Claims Act (FTCA) and seeking monetary damages associated with their loss of livestock following the implementation of a temporary fever tick quarantine.The Fifth Circuit affirmed the district court's dismissal for lack of jurisdiction, holding that plaintiffs' claims were barred by the quarantine exception to the FTCA. The quarantine exception states that the statute's sovereign immunity waiver does not apply to any claim for damages caused by the imposition or establishment of a quarantine by the United States. In this case, plaintiffs' damages were caused by the implementation of the quarantine and thus defendants' challenged actions fell within the exception. View "Cascabel Cattle Co., LLC v. United States" on Justia Law

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In this complaint seeking to have the Attorney General preliminarily and permanently enjoined from distributing monies received pursuant to an agreement between the Attorney General and Smithfield Foods, Inc. and several of its subsidiaries regarding the operation of hog farms to any recipient other than the Civil Penalty and Forfeiture Fund, the Supreme Court held that the payments contemplated by the agreement did not constitute penalties for purposes of N.C. Const. art. IX, 7.In their complaint, Plaintiffs argued that payments made pursuant to the agreement constituted penalties under article IX, section 7 and that the Attorney General lacked the authority to enter into the agreement. The trial court entered summary judgment in favor of the Attorney General, concluding that even if Smithfield and its subsidiaries had entered into the agreement in hope of avoiding future penalties, the payments made under the agreement were not penalties, forfeitures or fines collected for any breach of the penal laws of the State. The court of appeals reversed, concluding that genuine issues of material fact existed precluding summary judgment. The Supreme Court reversed, holding that the payments contemplated by the agreement did not constitute penalties for purposes of article IX, section 7. View "New Hanover County Board of Education v. Stein" on Justia Law

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House owns an organic farm, adjacent to the Property, formerly owned by Moller. In 2002, House entered into a six-year lease with Moller for 35 farmable acres, containing a renewal option and a right of first refusal. House converted the Property to certified organic status. In 2007, Moller, with no notice to House, agreed to sell the Property to Foss. Foss, a licensed real estate agent, prepared the agreement, which did not contain a fixed closing date. House became aware of the agreement, notified Foss about the right of first refusal, and sued Moller. While the lease remained in effect, Foss entered the Property and sprayed nonorganic herbicides, cut down trees, and altered the fencing. House sued Foss. Moller filed for bankruptcy. The Property was foreclosed on and sold to a third party in 2015.The trial court found Foss liable for inducing a breach of contract, intentionally interfering with House’s prospective economic advantage, conversion, trespass, and negligence and awarded compensatory damages of $1,669,705 and $1,000 in punitive damages. House sought attorney fees and costs. The court denied the motion. The court of appeal remanded for a determination of reasonable attorney fees under Code of Civil Procedure 1021.9, which refers to “any action to recover damages to personal or real property resulting from trespassing on lands either under cultivation or intended or used for the raising of livestock.” The damages award is supported by substantial evidence. View "Kelly v. House" on Justia Law

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Iscavo and Villita filed suit against defendant and his now-defunct product distribution company, Coram Deo, for violations of the Perishable Agricultural Commodities Act. The Fifth Circuit affirmed the district court's grant of summary judgment for Iscavo and Villita, holding that defendant was properly held personally liable for the amounts Coram Deo owed for avocados under the Act.The court affirmed the district court's award of attorney fees to Villita, but vacated and remanded the award of attorneys' fee to Iscavo for the district court to explain the basis for its award. In this case, it was unclear from the record whether Iscavo's invoice required Coram Deo to pay attorneys' fees incurred in Iscavo's collection efforts, and the district court gave no explanation for its award to Iscavo. View "Iscavo Avocados USA, LLC v. Pryor" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court granting summary judgment in favor of Defendant and dismissing Plaintiff's complaint alleging that Defendant's cattle trespassed onto his property causing damage to his sweet potato crop, holding that the legislature intended to hold owners of livestock liable for the damage caused by the trespass of their animals on cultivated land whether the land is properly fenced or not.In granting summary judgment for Defendant, the circuit court concluded (1) Hawai'i's statutory law governing the trespass of livestock onto cultivated land did not apply to Plaintiff's property because the property was neither "properly fenced" nor "unfenced"; and (2) a provision in Plaintiff's lease making Plaintiff fully responsible for keeping cattle out of his cultivated land was not void against public policy. The ICA affirmed. The Supreme Court reversed, holding (1) livestock owners are liable for damages caused by their livestock trespassing onto cultivated land; and (2) the lease provision was contrary to statutory law and public policy and was thus invalid because it had the effect of absolving Defendant of liability for livestock damage to Plaintiff's cultivated land. View "Yin v. Aguiar" on Justia Law

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Jeff Good and Harry’s Dairy entered into a contract providing that Harry’s Dairy would purchase 3,000 tons of Good’s hay. Harry’s Dairy paid for and hauled approximately 1,000 tons of hay over a period of approximately eight weeks, but did not always pay for the hay before hauling it and at one point went several weeks without hauling hay. After Harry’s Dairy went a month without hauling additional hay, Good demanded that Harry’s Dairy begin paying for and hauling the remaining hay. Harry’s Dairy responded that it had encountered mold in some of the hay, but would be willing to pay for and haul non-moldy hay at the contract price. Good then sold the remaining hay for a substantially lower price than he would have received under the contract, and filed a complaint against Harry’s Dairy alleging breach of contract. Harry’s Dairy counterclaimed for violation of implied and express warranties and breach of contract. The district court granted summary judgment in favor of Good on all claims, and a jury ultimately awarded Good $144,000 in damages. Harry’s Dairy appealed, arguing that there were several genuine issues of material fact precluding summary judgment, that the jury verdict was not supported by substantial and competent evidence, and that the district court erred in awarding attorney fees, costs, and prejudgment interest to Good. The Idaho Supreme Court determined the district court erred only in its decision with respect to Good’s breach of contract claim and Harry’s Dairy’s breach of the implied warranty of merchantability claims. Judgment was vacated and the matter remanded for further proceedings. View "Good v. Harry's Dairy" on Justia Law

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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

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Francisca Gomez died as the result of a horrific industrial accident while she was cleaning a seed sorting machine as part of her employment with the Crookham Company (“Crookham”). Her family (the Gomezes) received worker’s compensation benefits and also brought a wrongful death action. The Gomezes appealed the district court's decision to grant Crookham’s motion for summary judgment on all claims relating to Mrs. Gomez’s death. The district court held that Mrs. Gomez was working within the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims failed as a matter of law because Crookham was not a “manufacturer.” In affirming in part and reversing in part, the Idaho Supreme Court determined the trial court erred when it failed to consider whether Crookham committed an act of unprovoked physical aggression upon Mrs. Gomez by consciously disregarding knowledge that an injury would result. As such, the matter was remanded to the district court for further proceedings. View "Gomez v. Crookham" on Justia Law

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The Grossens own but do not live on, Parcel A, adjacent to Parcel B, leased by Frank. The parcels are separated by a common fence. Frank has used Parcel B for pasturing cattle since 2009 and, under his lease is responsible for maintaining the fences on the parcel. When Frank repaired the fence he did not notify the Grossens. In 2011, Frank’s cattle escaped to a nearby road, where Raab collided with a cow. Raab sued, citing the Animals Running Act. Frank filed a third-party complaint against the Grossens under the Contribution Act, citing the Fence Act, negligence, and breach of contract. The cow that injured Raab escaped through a portion of the fence the Grossens were obligated to maintain under a contract between previous owners. The circuit court approved a $225,000 settlement agreement between Raab and Frank; determined that the Animals Running Act barred any contribution from nonowners or nonkeepers of livestock and that Frank’s failure to notify the Grossens of known deficiencies in the fence barred liability under the Fence Act; and held that a breach of the fence contract could not create that liability to Raab, so the contract could not be the basis for contribution. The appellate court reversed in part.The Illinois Supreme Court held that common law does not provide a basis to hold a nonowner or nonkeeper of livestock liable in tort for damage caused by a neighbor’s animals; the Animals Running Act is not a source of a duty for nonowners and nonkeepers to restrain neighboring cattle. Since Frank has not otherwise established potential tort liability, breach of contract does not give rise to liability under the Contribution Act. View "Raab v. Frank" on Justia Law