John L. Durnell v. Monsanto Company

CourtMissouri Court of Appeals
DecidedFebruary 11, 2025
DocketED112410
StatusPublished

This text of John L. Durnell v. Monsanto Company (John L. Durnell v. Monsanto Company) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John L. Durnell v. Monsanto Company, (Mo. Ct. App. 2025).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION FOUR

JOHN L. DURNELL, ) No. ED112410 ) Respondent, ) Appeal from the Circuit Court ) of the City of St. Louis vs. ) 1922-CC00221 ) MONSANTO COMPANY, ) Honorable Timothy J. Boyer ) Appellant. ) Filed: February 11, 2025

Monsanto Company (“Monsanto”) appeals the judgment entered upon a jury verdict in

favor of John L. Durnell (“Plaintiff”) on Plaintiff’s claim for strict liability failure to warn. The

trial court’s judgment entered upon the jury’s verdict awarded Plaintiff $1.25 million in

compensatory damages. We affirm. 1

I. BACKGROUND

In January 2019, Plaintiff sued Monsanto alleging his exposure to Monsanto’s product

Roundup and its ingredient glyphosate caused him to develop non-Hodgkin’s lymphoma

(“NHL”). Plaintiff’s petition alleged claims for strict liability defective design, strict liability

failure to warn, and negligence.

The case proceeded to a jury trial beginning in September 2023. At the close of

1 Monsanto filed a motion, which was taken with the case, requesting this Court to take judicial notice of certain materials “which document or relate to key aspects of glyphosate’s regulatory history at the federal and state levels.” We deny Monsanto’s motion taken with the case. Plaintiff’s evidence and again at the close of all the evidence, Monsanto moved for a directed

verdict on the grounds that, inter alia, Plaintiff’s claims were expressly and impliedly preempted

by federal law. The trial court denied both motions for directed verdict.

The jury returned a verdict in favor of Plaintiff on his strict liability failure to warn claim,

but found in favor of Monsanto on Plaintiff’s strict liability defective design and negligence

claims. The jury awarded Plaintiff $1.25 million in compensatory damages, and the trial court

entered its judgment in accordance with the jury’s verdicts. Monsanto subsequently filed a

motion for judgment notwithstanding the verdict (“JNOV”) and in the alternative a new trial,

which again argued, inter alia, that federal law both expressly and impliedly preempted

Plaintiff’s strict liability failure to warn claim. The trial court denied Monsanto’s motion. This

appeal followed. 2

II. DISCUSSION

Monsanto raises a single point on appeal arguing the trial court erred in denying its

motion for JNOV because federal law both expressly and impliedly preempted Plaintiff’s strict

liability failure to warn claim (“failure to warn claim” or “claim”).

A. Standard of Review

“Federal preemption is a question of law this Court reviews de novo.” Collector of

Winchester v. Charter Communications, Inc., 660 S.W.3d 405, 416 (Mo. App. E.D. 2022).

Similarly, the trial court’s ruling challenged by Monsanto on appeal – the denial of a motion for

JNOV based on a matter of law – raises a question of law requiring de novo review. See Boggs

ex rel. Boggs v. Lay, 164 S.W.3d 4, 15 (Mo. App. E.D. 2005).

2 To avoid unnecessary repetition, additional facts relevant to Monsanto’s point on appeal will be set forth in Section II.B. of this opinion.

2 B. Analysis of Monsanto’s Sole Point on Appeal

When analyzing federal preemption of a state cause of action, “[i]t is assumed that the

historic police powers of the state are not preempted absent ‘the clear and manifest purpose of

Congress’ to do so.” Connelly v. Iolab Corp., 927 S.W.2d 848, 851 (Mo. banc 1996) (quoting

Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 (1947)). “[T]he purpose of Congress in

enacting the federal statute is the ultimate touchstone” in our analysis. Connelly, 927 S.W.2d at

851 (citing Malone v. White Motor Corp., 435 U.S. 497, 504 (1978)). Furthermore, preemption

of state law by statute may be either express or implied. Cooperative Home Care, Inc. v. City of

St. Louis, 514 S.W.3d 571, 579 (Mo. banc 2017). In this case, Monsanto argues Plaintiff’s

failure to warn claim is both expressly and impliedly preempted by federal law, and we proceed

by addressing each type of preemption in turn below.

1. Express Preemption

Express preemption occurs when a federal statute explicitly proscribes a local regulation

in a specific area. Id.; Stegall v. Peoples Bank of Cuba, 270 S.W.3d 500, 503 (Mo. App. S.D.

2008). The Federal Insecticide, Fungicide, and Rodenticide Act (“FIFRA”) – the federal

statutory scheme which Monsanto argues expressly preempted Plaintiff’s failure to warn claim –

regulates the use, sale, and labeling of pesticides. See 7 U.S.C. section 136 et seq.; Carson v.

Monsanto Company, 92 F.4th 980, 986 (11th Cir. 2024). FIFRA contains an express preemption

provision at 7 U.S.C. section 136v(b) (“section 136v(b)”) which provides that a “[s]tate shall not

impose or continue in effect any requirements for labeling or packaging in addition to or

different from those required under” FIFRA. Section 136v(b). In other words, FIFRA will

preempt a state law requirement – including a common-law cause of action – that is not fully

consistent with FIFRA’s requirements. Id.; Carson, 92 F.4th at 990-91 (citing Bates v. Dow

Agrosciences LLC, 544 U.S. 431, 447 (2005)). A state law requirement is not fully consistent

3 with FIFRA’s requirements when the state law requirement is: (1) for labeling or packaging; and

(2) in addition to or different from what FIFRA requires. Section 136v(b); Carson, 92 F.4th at

989-91 (citing Bates, 544 U.S. at 444, 446-47).

Monsanto does not dispute on appeal that Plaintiff’s successful failure to warn claim is a

common-law action which effectively imposes a state law requirement for labeling upon

Monsanto. 3 Accordingly, the dispositive question as to express preemption in this case is

whether Plaintiff’s failure to warn claim imposes a requirement that is “in addition to or different

from” FIFRA’s labeling requirements. See id.

FIFRA’s labeling requirements under 7 U.S.C. section 136(q)(1)(G) (“section

136(q)(1)(G)”) contain a prohibition on misbranding. Id.; Carson, 92 F.4th at 991. Section

136(q)(1)(G) provides in relevant part that “[a] pesticide is misbranded if . . . the label does not

contain a warning or caution statement which may be necessary and if complied with . . . is

adequate to protect health and the environment.” Id. This “prohibition on misbranding

effectively imposes a strict-liability standard,” holding a manufacturer liable for omitting a

warning regardless of knowledge or intent. Carson, 92 F.4th at 991-92.

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Related

Rice v. Santa Fe Elevator Corp.
331 U.S. 218 (Supreme Court, 1947)
Malone v. White Motor Corp.
435 U.S. 497 (Supreme Court, 1978)
Bates v. Dow Agrosciences LLC
544 U.S. 431 (Supreme Court, 2005)
Wyeth v. Levine
555 U.S. 555 (Supreme Court, 2009)
Arizona v. United States
132 S. Ct. 2492 (Supreme Court, 2012)
Boggs Ex Rel. Boggs v. Lay
164 S.W.3d 4 (Missouri Court of Appeals, 2005)
State v. MacK
66 S.W.3d 706 (Supreme Court of Missouri, 2002)
Stegall v. Peoples Bank of Cuba
270 S.W.3d 500 (Missouri Court of Appeals, 2008)
Connelly v. Iolab Corp.
927 S.W.2d 848 (Supreme Court of Missouri, 1996)
Doe v. Roman Catholic Archdiocese of St. Louis
311 S.W.3d 818 (Missouri Court of Appeals, 2010)
Moore v. Ford Motor Co.
332 S.W.3d 749 (Supreme Court of Missouri, 2011)
Edwin Hardeman v. Monsanto Company
997 F.3d 941 (Ninth Circuit, 2021)
Paul v. Jackson
910 S.W.2d 286 (Missouri Court of Appeals, 1995)
Mizner v. North River Homes, Inc.
913 S.W.2d 23 (Missouri Court of Appeals, 1995)
State v. Diaz-Rey
397 S.W.3d 5 (Missouri Court of Appeals, 2013)
Cooperative Home Care, Inc. v. City of St. Louis
514 S.W.3d 571 (Supreme Court of Missouri, 2017)
Mut. Pharm. Co. v. Bartlett
570 U.S. 472 (Supreme Court, 2013)
John Carson v. Monsanto Company
92 F.4th 980 (Eleventh Circuit, 2024)
David Schaffner, Jr. v. Monsanto Corp
113 F.4th 364 (Third Circuit, 2024)

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