CTM Holdings, LLC v. United States Department of Agriculture

CourtDistrict Court, N.D. Iowa
DecidedMay 29, 2025
Docket6:24-cv-02016
StatusUnknown

This text of CTM Holdings, LLC v. United States Department of Agriculture (CTM Holdings, LLC v. United States Department of Agriculture) is published on Counsel Stack Legal Research, covering District Court, N.D. Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CTM Holdings, LLC v. United States Department of Agriculture, (N.D. Iowa 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA EASTERN DIVISION

CTM HOLDINGS, LLC, an Iowa No. 24-CV-2016-CJW-MAR limited liability company, Plaintiff, MEMORANDUM OPINION AND ORDER vs. UNITED STATES DEPARTMENT OF AGRICULTURE; BROOKE ROLLINS, in her official capacity as the Secretary of the United States Department of Agriculture; NATURAL RESOURCES CONSERVATION SERVICE; LOUIS ASPEY, in his official capacity as Chief of the Natural Resources Conservation Service; and JON HUBBERT, in his official capacity as Iowa State Conservationist, Defendants.1

IOWA FARMERS UNION, IOWA ENVIRONMENTAL COUNCIL, FOOD & WATER WATCH, and DAKOTA RURAL ACTION, Intervenors. ___________________________

1 Originally, Thomas Vilsack was a named defendant as Secretary of the USDA, and Terry Cosby was a named defendant as Chief of the Natural Resources Conservation Service. Defendants note that these two officials have been replaced by the individuals now named in the caption. (Doc. 59, at 1 n.1). Consistent with Federal Rule of Civil Procedure 25(d), these officers’ successors are “automatically substituted as a party.” It appears that, perhaps, the NRCS has switched chiefs again since the parties’ most recent filings. But the Court will keep the caption consistent with that reflected in defendants’ most recent filings. Any error of this sort is of no consequence, as noted in Rule 25(d). TABLE OF CONTENTS

I. INTRODUCTION .......................................................................... 3

II. FACTUAL BACKGROUND ............................................................. 3

III. SUMMARY JUDGMENT STANDARD ............................................... 7

IV. ANALYSIS ................................................................................... 9

A. Defendants’ Motion for Summary Judgment ................................... 9

B. Intervenors’ Motion for Summary Judgment ..................................10

1. Standing .....................................................................11

2. Constitutionality of Swampbuster .......................................15

3. Unconstitutional Conditions ..............................................18

4. USDA Rule Defining “Converted Wetland” ..........................24

5. USDA Review Regulation ................................................28

V. PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT .........................28

VI. CONCLUSION .............................................................................29 I. INTRODUCTION There are several motions before the Court. Defendants filed a motion for summary judgment and a brief in support. (Docs. 56 & 59). Plaintiff resisted (Doc. 65) and defendants filed a reply (Doc. 72). Plaintiff also filed a motion for summary judgment and brief in support. (Docs. 57 & 57-1). Defendants resisted (Doc. 67) and plaintiff filed a reply (Doc. 71). Finally, intervenors filed a motion for summary judgment and/or dismissal (Doc. 54) as well as a number of other filings. (Docs. 66 & 70). Plaintiff’s resistance to defendants’ motion for summary judgment also resisted intervenors’ motion for summary judgment. (Doc. 65). On March 31, 2025, the Court heard oral argument on all three motions. (Doc. 73). For the following reasons, defendants’ and intervenors’ motions for summary judgment (Docs. 56 & 54) are granted and plaintiff’s motion for summary judgment (Doc. 57) is denied. II. FACTUAL BACKGROUND In September 2022, plaintiff purchased three contiguous parcels of land consisting of 71.85 acres in Delaware County, Iowa. (Doc. 67-1, at 2). James Conlan is plaintiff’s principal owner. (Doc. 65-1, at 2). The previous owner of the land used about forty acres for agriculture, enrolled about 10 acres in the Conservation Reserve Program, and the remaining approximately twenty-one acres were forested. (Doc. 67-1, at 2). The Conservation Reserve Program contract—under which the government made payments to the landowner to conserve the land—expired in 2024. (Id.). In 2010, the United States Department of Agriculture (“USDA”) determined that nine of the twenty-one forested acres were “wetland.” (Id.). When plaintiff was under contract to purchase the land, Conlan began emailing with USDA representatives regarding wetland determinations. (Id., at 3). Initially, in July 2022, Conlan asked for the employee’s “help with the process of seeking” a redetermination of the nine acres previously denoted as wetlands, among other things. (Doc. 56-2, at 58–59). Conlan noted that one of his plans for the property was to remove trees from several areas of the property. (Id.). In August 2022, a USDA employee emailed Conlan regarding several things. The employee noted, in part, that “any logging or widespread tree removal could potentially create a wetland violation situation” and a wetland violation “would jeopardize all financial benefits associated to the farm, including those of any tenants associated to the farm, and possibly their other farming interests.” (Id., at 56). The employee’s point, it seems, was to explain that plaintiff would be wise to request a wetland determination for the land which previously had not had a wetland determination. On October 7, 2022, Conlan signaled in an email that he wanted to remove the trees (but not the stumps) from the existing wetland, and remove the trees and stumps from the rest of the forested land (upon which no wetland determination had been made) to make that land ready for farming. (Id., at 54–55). On October 11 and 12, 2022, several USDA representatives told Conlan in emails that, because plaintiff planned on removing trees and stumps in the undetermined land (i.e., the land upon which no wetland determination had been made), plaintiff would need to submit a form AD-1026 to get a wetland determination completed on the then- undetermined land. (Id., at 51–53). On October 12, 2022, plaintiff signed and submitted a form AD-1026. (Doc. 57- 6, at 9–10). The form is entitled “Highly Erodible Land Conservation (HELC) and Wetland Conservation (WC) Certification.” (Id.). Plaintiff claims it submitted the form for several reasons, including “requesting a wetlands redetermination.” (Doc. 57-2, at 2). Defendants disagree. Defendants state that plaintiff’s purpose in submitting the form was to “delineate the wetland areas in advance of [plaintiff]’s plan to remove trees on both wetland and non-wetland areas.” (Doc. 67-1, at 4). Defendants further state that submission of a form AD-1026 “is not a request for review of an existing wetland determination, and nothing on the Form AD-1026 [plaintiff] submitted indicated that [plaintiff] intended to request a review.” (Id.). Plaintiff cites to a declaration by Conlan wherein Conlan states that his purpose in submitting the form AD-1026 was to request a wetlands redetermination, among other things. (Doc. 57-3, at 8). Plaintiff also cites to a string of emails which include, mostly, USDA and Natural Resources Conservation Service (“NRCS”) employees’ internal emails discussing how to mark plaintiff’s land (as had been requested by plaintiff) so plaintiff knew which land had been determined as a wetland previously. (Doc. 57-5, at 2–4). The employees also discussed in the emails recommending to Conlan that he fill out a form AD-1026 for non-inventoried areas. (Id.). Non-inventoried areas are areas for which no wetland determination has previously been made. Defendants cite to the filled out form AD-1026, which, as defendants state, says nothing about a redetermination. (Doc. 56-2, at 31–33).

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Bluebook (online)
CTM Holdings, LLC v. United States Department of Agriculture, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ctm-holdings-llc-v-united-states-department-of-agriculture-iand-2025.