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Administrative Law Keyed to Funk
Monsanto Co. v. Geertson Seed Farms
Citation:
561 U.S. 139, 130 S.Ct. 2743 (2010)Facts
Monsanto developed Roundup Ready Alfalfa (RRA), a variety of alfalfa that has been genetically engineered to be tolerant to glyphosate, the active ingredient in Monsanto’s herbicide Roundup. In 2004, Monsanto and Forage Genetics International (FGI) sought nonregulated status for RRA from APHIS. APHIS prepared an environmental assessment and decided to completely deregulate RRA without preparing an environmental impact statement (EIS). Following this decision, approximately 3,000 farmers planted an estimated 220,000 acres of RRA.
Respondents filed suit challenging APHIS’s decision. The District Court held that APHIS violated NEPA by failing to prepare an EIS before deregulating RRA, finding that APHIS’s environmental assessment failed to address substantial questions concerning the risk of gene flow from RRA to conventional alfalfa and the development of Roundup-resistant weeds. The court vacated APHIS’s deregulation decision, ordered APHIS to prepare an EIS before making any decision on Monsanto’s deregulation petition, and enjoined almost all future planting of RRA pending completion of the EIS. The court allowed farmers who had already purchased or planted RRA to harvest their crops.
APHIS and Monsanto proposed a compromise that would have allowed continued planting of RRA subject to certain conditions, but the District Court rejected this proposal. The Court of Appeals affirmed, finding that the District Court had not abused its discretion in rejecting APHIS’s proposed mitigation measures in favor of a broader injunction.
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