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Keywords

plaintiffinjunctionappealwillregulation
plaintiffinjunctionwillintellectual propertyregulationrespondent

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Monsanto Co. v. Geertson Seed Farms, 561 U.S. 139, 130 S.Ct. 2743, 177 L.Ed.2d 461, 70 ERC 1481, 78 USLW 4665, 08 Cal. Daily Op. Serv. 7714, 2010 Daily Journal D.A.R. 9305, 22 Fla. L. Weekly Fed. S 524

Facts

This case involves a challenge to the Animal and Plant Health Inspection Service's (APHIS) decision to deregulate Roundup Ready Alfalfa (RRA), a genetically engineered crop. The plaintiffs, conventional alfalfa growers and environmental groups, argued that APHIS violated the National Environmental Policy Act (NEPA) by failing to prepare an environmental impact statement (EIS) before deregulating RRA. The District Court agreed, issuing an injunction against the planting of RRA until an EIS was completed. The case was appealed, leading to a review of the standing of both parties and the appropriateness of the injunction.

This case involves Roundup Ready Alfalfa (RRA), a kind of alfalfa crop that has been genetically engineered to be tolerant of glyphosate, the active ingredient of the herbicide Roundup. Petitioners Monsanto Company (Monsanto) own the intellectual property rights to RRA. Monsanto licenses those rights to co-petitioner Forage Genetics International (FGI), which is the exclusive developer of RRA seed.

Issue

Did the District Court err in granting a nationwide injunction against the planting of genetically altered Roundup Ready Alfalfa pending the completion of an environmental impact statement?

Did the District Court err in granting a nationwide injunction against the planting of genetically altered Roundup Ready Alfalfa pending the completion of an environmental impact statement?

Rule

Under the National Environmental Policy Act (NEPA), federal agencies must prepare an environmental impact statement (EIS) for major federal actions significantly affecting the quality of the human environment. An agency may not need to complete an EIS if it finds, based on an environmental assessment (EA), that the proposed action will not have a significant environmental impact. Additionally, standing under Article III requires that the injury be concrete, particularized, and actual or imminent, fairly traceable to the challenged action, and redressable by a favorable ruling.

In deciding whether to grant nonregulated status to genetically engineered plant variety, Animal and Plant Health Inspection Service (APHIS) must comply with NEPA, which requires federal agencies, to the fullest extent possible, to prepare environmental impact statement (EIS) for every recommendation or report on proposals for legislation and other major federal action significantly affecting quality of the human environment; statutory text speaks solely in terms of proposed actions and does not require agency to consider possible environmental impacts of less imminent actions when preparing impact statement on proposed actions.

Analysis

The court found that the District Court abused its discretion by issuing a nationwide injunction against the planting of RRA. The plaintiffs could not demonstrate that they would suffer irreparable injury if APHIS were allowed to proceed with partial deregulation. The court noted that the existence of a NEPA violation does not automatically warrant injunctive relief, and the plaintiffs failed to satisfy the four-factor test for granting a permanent injunction.

None of the four factors supports the District Court's order enjoining APHIS from partially deregulating RRA during the pendency of the EIS process. Most importantly, respondents cannot show that they will suffer irreparable injury if APHIS is allowed to proceed with any partial deregulation, for at least two reasons. First, if and when APHIS pursues a partial deregulation that arguably runs afoul of NEPA, respondents may file a new suit challenging such action and seeking appropriate preliminary relief. Accordingly, a permanent injunction is not now needed to guard against any present or imminent risk of likely irreparable harm.

Conclusion

The Supreme Court reversed the District Court's injunction, holding that the plaintiffs did not meet the necessary criteria for such relief and that the District Court had abused its discretion.

The District Court abused its discretion in enjoining APHIS from effecting a partial deregulation and in prohibiting the planting of RRA pending the agency's completion of its detailed environmental review.

Who won?

The prevailing party in this case was the petitioners, Monsanto Company and Forage Genetics International, who sought to challenge the District Court's injunction against the planting of RRA. The Supreme Court found that the plaintiffs did not demonstrate the requisite standing or irreparable harm necessary to justify the injunction, thus favoring the petitioners' position.

The prevailing party in this case was the petitioners, Monsanto Company and Forage Genetics International, who successfully challenged the District Court's injunction against the planting of RRA, as the Supreme Court found that the plaintiffs did not meet the necessary criteria for such relief.

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