RUCKELSHAUS V. MONSANTO CO. 467 U.S. 986 (1984) CASE BRIEF

RUCKELSHAUS V. MONSANTO CO.

467 U.S. 986 (1984)

NATURE OF THE CASE: This was a dispute over the use of applicant data on pesticides. The District Court therefore declared 3(c)(1)(D), 3(c)(2)(A), 10(b), and 10(d) of FIFRA, as amended by the Federal Pesticide Act of 1978, to be unconstitutional, and permanently enjoined EPA (D) from implementing or enforcing those sections.

FACTS: FIFRA was transformed from a labeling law to a comprehensive regulatory scheme by the Federal Environmental Pesticide Control Act of 1972. The most significant amendment pertained to the pesticide registration procedure and public disclosure of information learned through the procedure. EPA was allowed to consider data submitted by one applicant for registration in support of another pertaining to a similar chemical, provided the subsequent applicant offered to compensate the applicant who originally submitted the data. Any data designated as trade secrets or commercial or financial information was exempt from disclosure and could not be considered at all by EPA to support another registration application unless the original submitted consented. By another amendment in 1978, applicants were granted a 10-year period of exclusive use for data on new active ingredients contained in pesticides registered after September 30, 1978. All other data submitted after December 31, 1969, may be cited and considered in support of another application for 15 years after the original submission if the applicant offered compensation to the original submitter. The statute also stated that if an original submitter refused to engage in negotiations or arbitration he forfeited his claim for compensation. Data regarding health, safety, and environmental data was disclosed to qualified requesters despite the prohibition against disclosure of trade secrets. Monsanto (P) was a company engaged in the production of both active ingredients and end use products. It was an established fact that the development of a potential commercial pesticide requires $5-15 million annually for several years. It is also a fact that the average company screens 20,000 compounds before finding one that is acceptable for development. P was better than the average in that it screened about 10,000 compounds for every one that is commercially developed. P has submitted information on the registration process as required by law that was worth in excess of $23.6 million. P sought an injunction and declaratory relief from the operation of the data consideration provisions of section 3(c)(1)(P) and the data disclosure provisions of section 10 and the related section 3(c)(2)(A). P alleged that all the provisions affected a taking of its property without just compensation and that they affected a taking for a private use and not a public one. The District Court agreed and declared the sections unconstitutional and permanently enjoined P from implementing or enforcing those sections.

ISSUE:

RULE OF LAW:

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LEGAL ANALYSIS:

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