"The District Court abused its discretion in enjoining APHIS from effecting a partial deregulation and in prohibiting the planting of RRA pending the agency’s completion of its detailed environmental review.
As of 2010, alfalfa is the 4th largest cash crop and grows on approximately 20 million acres (81,000 km2) of land throughout the United States.
[1] The petitioner, Monsanto, is the owner and licensor of the intellectual property rights to RRA, and licenses the technology to Forage Genetics, developer of the Roundup Ready alfalfa seed.
The 537 opponents were mainly organic and conventional farmers who feared that cross-pollination would occur and would have detrimental effects on the alfalfa market.
This case arose from the 2005 decision made by the Animal and Plant Health Inspection Service (APHIS), an arm of the U.S. Department of Agriculture (USDA).
APHIS ( the defendant) performs a variety of services and is tasked with both protecting and promoting U.S. agricultural health and regulating genetically modified organisms.
APHIS responded favorably to Monsanto's request, but the deregulation was put on hold when Geertson Seed Farms (an Oregon Company), Trask Family Seeds (a South Dakota business) and other environmental groups sought to permanently enjoin APHIS from deregulating RRA until a final Environmental Impact Statement was completed.
Its analysis turned on the following questions:[1] It was noted that no party challenged the fact that APHIS had violated NEPA and that vacating the deregulation was within the District Court's discretion.
The District Court abused its discretion by enjoining APHIS from effecting a partial deregulation and in prohibiting the planting of RRA pending the agency’s completion of its detailed environmental review.
[1] The Supreme Court also stated that if a partial deregulation presented further danger to the respondents, they may file another suit for injunctive relief.
[1] It was also held that because the District Court did not consider the use of a less extraordinary measure to relieve the injury claimed by Geertson, the injunction was inappropriate.
The majority's understanding and its implications were not the subject of briefs nor extended arguments, and Stevens therefore dissented because "the key legal premise on which the Court decides this case was never adequately presented.
"[1] In Stevens' dissent, he maintained that the injunction was warranted because there was a clear danger that cross-pollination could happen, even in controlled settings, and that APHIS's ability to regulate and prevent this contamination was limited.