Anderson v. Dow Agrosciences LLC

262 F. Supp. 2d 1280, 51 U.C.C. Rep. Serv. 2d (West) 686, 2003 U.S. Dist. LEXIS 13137, 2003 WL 21182933
CourtDistrict Court, W.D. Oklahoma
DecidedMay 14, 2003
DocketCIV-01-1939-HE
StatusPublished
Cited by4 cases

This text of 262 F. Supp. 2d 1280 (Anderson v. Dow Agrosciences LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Dow Agrosciences LLC, 262 F. Supp. 2d 1280, 51 U.C.C. Rep. Serv. 2d (West) 686, 2003 U.S. Dist. LEXIS 13137, 2003 WL 21182933 (W.D. Okla. 2003).

Opinion

ORDER

HEATON, District Judge.

This case is before the Court on defendant’s motion for summary judgment. Plaintiffs have responded in opposition to the motion. Upon review, the Court determines defendant’s motion should be granted in part and denied in part. 1

Summary judgment is appropriate “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” Fed.R.Civ.P. 56(c). When applying this standard, the court “view[s] the evidence and draw[s] all reasonable inferences therefrom in the light most favorable to the party opposing summary judgment.” Martin v. Kansas, 190 F.3d 1120, 1129 (10th Cir.1999) overruled on other grounds Bd. of Trustees of Univ. of Ala. v. Garrett, 531 U.S. 356, 121 S.Ct. 955, 148 L.Ed.2d 866 (2001). “Only disputes over facts that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment.” Martin, 190 F.3d at 1129.

BACKGROUND

Defendant is the manufacturer of “Strongarm,” 2 a herbicide used to control weeds in peanut crops. Plaintiffs are a group of Oklahoma peanut farmers who purchased Strongarm for use on their peanut crops in the year 2000. 3 Plaintiffs contend the application of Strongarm to their fields caused various injuries to the sprouting peanut plants such that they did not grow properly, resulting in a significant reduction in yield and profits. 4 Plain *1284 tiffs assert that the damage caused by Strongarm impacted their 2000, 2001, and 2002, harvests and will continue to cause damage to their soil and subsequent crops.

Plaintiffs raise claims under Oklahoma law for negligence, violation of the Oklahoma Consumer Protection Act, breach of express and implied warranties, fraud and fraud in the inducement, estoppel and waiver, negligent representation, and strict liability. Defendant has filed a motion for summary judgment arguing plaintiffs’ claims are either barred under 2 Okla. Stat. § 3-82(H), preempted under the Federal Insecticide, Fungicide, and Roden-ticide Act (FIFRA), or fail to state a claim. 5

DISCUSSION

A. 2 OKLA STAT. § 3-82(H)

Defendant first asserts that all of plaintiffs’ claims, except those of plaintiff Mike Lovell, are barred by the application of 2 Okla. Stat. § 3-82(H), which states:

No action for alleged damages to growing annual crops or plants may be brought or maintained unless the person claiming the damages has filed with the Board [of Agriculture] a written statement of alleged damages on a form prescribed by the Board within ninety (90) days of the date that the alleged damages occurred, or prior to the time that twenty-five percent (25%) of a damaged crop has been harvested.

Plaintiffs admit that, except for plaintiff Lovell, none of the plaintiffs notified the Board of Agriculture about the damage to their crops. Plaintiffs argue, however, that the statutory provision does not apply to their particular claims. Specifically, plaintiffs assert that the provision applies only to claims against licensed pesticide applicators, not claims against pesticide manufacturers. Upon review of the statutory provision and its history, the Court agrees that plaintiffs’ claims are not barred.

Defendant’s argument as to the application of Section 3-82(H) is dependent on the Oklahoma Legislature’s 2000 amendment of the statute applying to this case, as it is the 2000 amendments which arguably add sellers and distributors of pesticides as persons subject to the statute’s reporting/damages-limiting provision. 6 As a threshold matter, there is considerable doubt whether the 2000 amendments have any application here due to the timing of the events giving rise to this case. The Strongarm product was purchased and applied in the spring of 2000. The 2000 amendments to Section 3-82(H) were not effective until June 6, 2000. There is at least some indication in the submitted materials that problems with the affected *1285 peanut crops were appearing “several weeks” prior to July, 2000. 7 Plaintiffs’ claims may therefore have accrued prior to the adoption of the 2000 amendment to Section 3-82(H).

Apart from any timing issues, the dispositive issue is whether Section 3-82(H) is potentially applicable to claims against pesticide manufacturers. The various rules of statutory construction alluded to by the parties point in different directions and the issue is not free from doubt. However, the positioning of the 3-82(H) language in the re-codified statute— immediately following the portions applying to applicators — suggests the legislature intended to continue to apply its damages-limiting provisions to those persons to whom it had previously applied — applicators. Had the legislature intended its restructuring of Section 3-82 to extend the damages limitation provision to manufacturers, it would likely have said so clearly and would have done so, if not by express words, then by at least positioning the applicable provision at the end of the statute where its applicability to all persons within the statute’s scope would have been more clear. In any event, the Court concludes Section 3-82(H) continues to apply only to claims against licensed pesticide applicators, not pesticide manufacturers. Defendant’s motion, insofar as it is based on the potential application of Section 3-82(H), is denied.

B. FEDERAL PREEMPTION UNDER FIFRA

FIFRA regulates the use and sale of pesticides and herbicides in the United States. Under FIFRA, all herbicides sold in the United States must be registered with the Environmental Protection Agency (EPA). 7 U.S.C. § 136a(a). As part of the registration process, a-herbicide manufacturer must submit a statement addressing, among other things, the composition of the herbicide, directions for its use, and all claims to be made for it. 7 U.S.C. § 136a(c).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hydronic Energy v. Rentzel Pump Mfg.
Nebraska Court of Appeals, 2013
Young v. Spencer
2011 OK CIV APP 79 (Court of Civil Appeals of Oklahoma, 2011)
Peterson v. BASF Corp.
675 N.W.2d 57 (Supreme Court of Minnesota, 2004)
Mortellite v. Novartis Crop Protection, Inc.
278 F. Supp. 2d 390 (D. New Jersey, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
262 F. Supp. 2d 1280, 51 U.C.C. Rep. Serv. 2d (West) 686, 2003 U.S. Dist. LEXIS 13137, 2003 WL 21182933, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-dow-agrosciences-llc-okwd-2003.