MONSANTO CO. V. GEERTSON SEED FARMS
130 S.Ct. 2743 (2010)
NATURE OF THE CASE: Monsanto (D) appealed a judgment that imposed an injunction on the
planting of genetically modified seeds.
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.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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