Monsanto Co. v. Geertson Seed Farms

130 S.Ct. 2743 (2010)

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Nature of the Case

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Facts

Monsanto (D) owns the intellectual property rights to a seed for genetically engineered alfalfa. Monsanto licenses those rights to Forage Genetics International. APHIS decided to deregulate this variety of genetically engineered alfalfa. Approximately eight months after APHIS granted nonregulated status, Geertson (P) (conventional alfalfa seed farms and environmental groups concerned with food safety) filed this action against the Secretary of Agriculture and certain other officials in Federal District Court, challenging APHIS's decision to completely deregulate the seed. The District Court held that APHIS violated the National Environmental Policy Act of 1969 without first completing a detailed assessment of the environmental consequences of its proposed course of action. The District Court vacated the agency's decision. The District Court granted Ds permission to intervene in the remedial phase of the lawsuit. The Court of Appeals affirmed the District Court's entry of permanent injunctive relief. The District Court rejected APHIS's proposed judgment. In its preliminary injunction, the District Court prohibited almost all future planting of the seed pending APHIS's completion of the required EIS. But in order to minimize the harm to farmers who had relied on APHIS's deregulation decision, the court expressly allowed those who had already purchased the seed to plant their seeds until March 30, 2007. In its subsequently entered permanent injunction and judgment, the court (1) vacated APHIS's deregulation decision; (2) ordered APHIS to prepare an EIS before it made any decision on D's deregulation petition; (3) enjoined the planting of any seed in the United States after March 30, 2007, pending APHIS's completion of the required EIS; and (4) imposed certain conditions (suggested by APHIS) on the handling and identification of already-planted seed. D appealed, challenging the scope of the relief granted but not disputing the existence of a NEPA violation. A divided panel of the Court of Appeals for the Ninth Circuit affirmed. The Supreme Court granted certiorari, and the casebook only addresses the issue of standing to seek injunctive relief. Ds contend that Ps lack standing to seek injunctive relief.