Justia Civil Procedure Opinion Summaries

Articles Posted in Agriculture Law
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The case involves Aerie Point Holdings, LLC (Aerie Point) and Vorsteveld Farm, LLC (Vorsteveld). Aerie Point owns a property in Panton, Vermont, which is located downhill from Vorsteveld's dairy farm. In 2017, Vorsteveld began installing tile drains in its fields to improve soil quality. The excess water drained from these tiles was discharged into public ditches, then through culverts, and finally towards Lake Champlain over Aerie Point’s property. This led to increased water flow, sediment, and contaminants on Aerie Point's land, causing shoreline erosion and algae blooms in Lake Champlain. In April 2020, Aerie Point filed a lawsuit against Vorsteveld for trespass and nuisance.The civil division found in favor of Aerie Point in March 2022, concluding that Vorsteveld's actions constituted trespass and nuisance. The court issued an injunction in August 2022, preventing Vorsteveld from allowing water from its drain tile system to flow into the public ditches and culverts on Arnold Bay Road. Vorsteveld did not appeal this judgment.In August 2023, Vorsteveld moved for relief from the judgment under Rule 60(b)(5) and (6), arguing that postjudgment changes in fact and law justified relief from the injunction. Vorsteveld claimed that an Environmental Protection Agency (EPA) investigation regarding filled wetlands on the farm prevented it from complying with the injunction, and that the federal investigation/enforcement action preempted the state injunction. Vorsteveld also argued that changes to Vermont’s Right-to-Farm law justified relief from the injunction. The court denied the motion and the request for an evidentiary hearing.On appeal, the Vermont Supreme Court affirmed the lower court's decision. The court found that Vorsteveld's arguments were attempts to relitigate issues that had been resolved by the judgment. The court also found that Vorsteveld had not demonstrated that there were significant postjudgment changes in factual circumstances or the law that made prospective application of the injunction inequitable. The court concluded that Vorsteveld's arguments relating to the EPA investigation and changes to the Right-to-Farm law were insufficient to merit relief under Rule 60(b). The court also found that the trial court did not abuse its discretion in denying Vorsteveld's request for an evidentiary hearing. View "Aerie Point Holdings, LLC v. Vorsteveld Farm, LLC" on Justia Law

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The case involves J and L Farms, Inc. (J&L), a South Dakota company, and First Bank, a Florida banking corporation. J&L had an ongoing business relationship with Jackman Wagyu Beef, LLC (Jackman), a Florida-registered company, where Jackman would purchase cattle from J&L. In 2018, Jackman proposed a change in their payment terms, offering to pay for the cattle within 30 days of placing an order, instead of paying prior to the cattle being shipped. To secure each payment, Jackman proposed that J&L would be given a bank guarantee from First Bank. First Bank issued three separate guaranty letters to J&L to secure payment for the sale of cattle. However, Jackman failed to provide full payment for two orders, and First Bank refused to satisfy the outstanding balance.The circuit court of the Fifth Judicial Circuit in Brown County, South Dakota, entered a default judgment against Jackman after it failed to plead or defend against J&L’s complaint. First Bank filed a motion to dismiss for lack of personal jurisdiction, arguing that it did not have sufficient minimum contacts for a South Dakota court to exercise personal jurisdiction over it. The circuit court denied the motion.The Supreme Court of the State of South Dakota affirmed the circuit court's decision. The Supreme Court found that First Bank had sufficient minimum contacts with South Dakota to establish personal jurisdiction. The court reasoned that First Bank purposefully availed itself of the privileges of acting in South Dakota by issuing three guaranty letters to J&L, a South Dakota company, to facilitate the purchase of South Dakota cattle. The court also found that the cause of action against First Bank arose from its activities directed at South Dakota, and that the acts of First Bank had a substantial connection with South Dakota, making the exercise of jurisdiction over First Bank reasonable. View "J&l Farms" on Justia Law

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An elderly woman, Janice Geerdes, and her long-time friend, Albert Gomez Cruz, had a partnership raising hogs on a piece of land. Initially, Janice deeded half of her interest in the land to Albert. Over a decade later, she deeded the rest of her interest in the land to Albert, receiving nothing in return. About six months later, Janice’s adult daughters were appointed her conservator and guardian. The conservator challenged the validity of the quitclaim deed based on undue influence and lack of capacity.The district court set aside the deed, finding that there was undue influence through a confidential relationship and that Janice lacked the necessary capacity to deed her interest in the land. The court of appeals affirmed the decision on the basis of lack of capacity.The Supreme Court of Iowa, however, disagreed with the lower courts. The Supreme Court found that the conservator did not establish by clear, convincing, and satisfactory evidence that there was undue influence or that Janice lacked capacity at the time of the gift. The court found that the lower courts gave too much weight to the perceived improvidence of the transaction and too little weight to the testimony of the third-party accountant who witnessed the transaction. Therefore, the Supreme Court vacated the decision of the court of appeals, reversed the district court judgment, and remanded for further proceedings. View "Conservatorship of Janice Geerdes v. Cruz" on Justia Law

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Bader Farms, Inc. sued Monsanto Company and BASF Corporation, alleging that its peach orchards were damaged by dicamba drift between 2015 and 2019 due to the defendants' negligent design and failure to warn. The jury awarded $250 million in punitive damages against both Monsanto and BASF based on Monsanto’s acts in 2015-16, which the district court later reduced to $60 million. The defendants appealed the decision.The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision except for punitive damages, holding BASF and Monsanto liable as co-conspirators in a civil conspiracy. The court remanded the case to separately assess punitive damages against Monsanto and BASF. However, before the new trial, Monsanto settled with Bader Farms. The district court did not conduct a new trial and instead ruled that BASF could not be liable for any punitive damages, dismissing all claims against BASF.Bader Farms appealed, arguing that the district court ignored the appellate court’s mandate and its holding that BASF could be assessed punitive damages for its acts in furtherance of the conspiracy. The appellate court reviewed the district court’s interpretation of its mandate de novo and found that the district court did not comply with the appellate mandate. The appellate court held that BASF is vicariously liable for Monsanto’s actions and remanded the case for a trier of fact to apportion the punitive damages award. The court reversed the judgment and remanded with instructions to hold a new trial on the single issue of punitive damages. View "Bader Farms, Inc. v. BASF Corporation" on Justia Law

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The case in question pertains to a dispute over the enforceability of dragnet clauses within mortgages used to secure loans funding Frank Welte’s farming operations. The Vera T. Welte Testamentary Trust, of which Frank Welte is the sole beneficiary, pledged its property as security for these loans, which were provided by Roger Rand, another Iowa farmer. The Trust's primary asset is 160 acres of farmland that were leased to Frank. Upon Rand's death, his estate initiated a foreclosure action against the Trust's farmland. The Trust subsequently filed for chapter 12 bankruptcy, which led to a stay of the foreclosure action against the Trust.The Estate filed a proof of claim and a motion to dismiss the Trust’s bankruptcy petition, alleging that the Trust was not a business trust as required by chapter 12. The Trust objected to the Estate’s proof of claim. The Iowa state court ruled that the dragnet clauses in the mortgage documents secured the loans made to Frank in excess of the face amount of the promissory notes.The United States Bankruptcy Court for the Northern District of Iowa, however, held that the dragnet clauses were not enforceable, thereby concluding that the Trust no longer owed a debt to the Estate. Following this, the United States District Court for the Northern District of Iowa gave preclusive effect to the judgment of the Iowa Court of Appeals concerning the enforceability of the clauses and the amounts owed thereunder.The Trust and the Estate both appealed the district court’s order. The United States Court of Appeals for the Eighth Circuit dismissed the appeal and cross-appeal due to lack of jurisdiction, as the district court's order was not final and required further proceedings in the bankruptcy court. View "The Security National Bank of Sioux City, IA v. Vera T. Welte Testamentary Trust" on Justia Law

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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

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This case revolves around a long-standing dispute between two Nebraska families, the Zeilers and the Reifschneiders, over rights to divert water from their neighboring farmland. The dispute lead to a consent judgment in 1988, where Zeiler's father was ordered to remove a dike and level the area to a uniform elevation to allow for the drainage of surface waters from the Zeiler property to the Reifschneider property. Years later, Michael Zeiler filed a contempt action against Kenneth E. Reifschneider, alleging that Reifschneider had violated the consent judgment by raising the elevation level along the property boundary line, causing water to pool on Zeiler's farmland. The district court found Reifschneider in contempt, concluding he had willfully violated the consent judgment.However, the Nebraska Supreme Court vacated the district court's decision and dismissed the appeal. The Supreme Court concluded that Zeiler lacked standing to pursue the contempt action because the consent judgment did not impose any obligations on Reifschneider. The judgment was a compromise conclusion to the earlier litigation between Reifschneider and Zeiler's father, where the defendant provided consideration in exchange for the plaintiff's dismissal of suit. The court clarified that its decision determined only that Zeiler lacked standing to pursue a contempt action, and made no evaluation of whether Zeiler would have standing or could obtain relief against Reifschneider via a different legal theory. View "Zeiler v. Reifschneider" on Justia Law

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In April 2012, Plaintiff-Appellee Brandon Barrick filed a qui tam action against his then-employer, Defendant-Appellant Parker-Migliorini International LLC (PMI). Barrick alleged violations of the False Claims Act (FCA) and amended his complaint to include a claim that PMI unlawfully retaliated against him under the FCA. PMI was a meat exporting company based in Utah. While working for PMI, Barrick noticed two practices he believed were illegal. The first was the “Japan Triangle”: PMI exported beef to Costa Rica to a company which repackaged it, then sent it to Japan (Japan had been concerned about mad cow disease from U.S. beef). The second was the “LSW Channel”: PMI informed the U.S. Department of Agriculture (USDA) it was shipping beef to Moldova on a shipping certificate, but sent it to Hong Kong. Then, according to Barrick, PMI smuggled the beef into China (China was not then accepting U.S. beef). Barrick brought his concerns to Steve Johnson, PMI’s CFO, at least three times, telling Johnson that he was not comfortable with the practices. By October, the FBI raided PMI's office. Barrick was terminated from PMI in November 2012, as part of a company-wide reduction in force (RIF). PMI claimed the RIF was needed because in addition to the FBI raid, problems with exports and bank lines of credit put a financial strain on the company. Nine employees were terminated as part of the RIF. PMI claims it did not learn about Barrick’s cooperation with the FBI until October 2014, when the DOJ notified PMI of this qui tam action. A jury found that PMI retaliated against Barrick for his engagement in protected activity under the FCA when it terminated his employment. On appeal, PMI argued the district court improperly denied its motion for judgment as a matter of law (JMOL). In the alternative, PMI argued the Tenth Circuit court should order a new trial based on either the district court’s erroneous admission of evidence or an erroneous jury instruction. Finding no reversible error, the Tenth Circuit affirmed on all issues. View "Barrick v. Parker-Migliorini International" on Justia Law

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Plaintiff 65282 Two Bunch Palms Building LLC, (Two Bunch) orally leased an industrial building in Desert Hot Springs to Coastal Harvest II, LLC, (Coastal Harvest) for the indoor cultivation of cannabis. When, after two years of negotiations, the parties were unable to agree to a written lease and a master service agreement, Two Bunch served Coastal Harvest with a 30-day notice to quit. Coastal Harvest refused to vacate the property, so Two Bunch instituted this unlawful detainer action. After a one-day trial, the trial court entered a judgment of possession for Two Bunch and awarded it $180,000.13 in holdover damages. At trial court, Coastal Harvest unsuccessfully argued it operated a licensed cannabis operation on the property and, therefore, it could not be evicted because it was entitled to the presumption under California Civil Code section 1943 of a one-year tenancy for “agricultural . . . purposes” and the presumption of a one-year holdover tenancy for use of “agricultural lands” under Code of Civil Procedure section 1161(2). Assuming without deciding that Coastal Harvest’s cannabis operation constituted agriculture, Two Bunch rebutted the presumption under Civil Code section 1943 with evidence that the parties agreed that, unless they signed a written lease, the term of the oral lease was month-to-month. And, because this unlawful detainer action was not filed for failure to pay rent, Code of Civil Procedure section 1161(2) and its holdover presumption for “agricultural” tenants did not apply. Finding no reversible error in the trial court's judgment, the Court of Appeal affirmed. View "65282 Two Bunch Palms Building LLC v. Coastal Harvest II, LLC" on Justia Law

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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