BATES v. DOW AGROSCIENCES LLC

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Case Basics
Docket No. 
03-388
Petitioner 
Dennis Bates, et al.
Respondent 
Dow Agrosciences LLC
Advocates
(argued the cause for Respondent, on behalf of the United States, as amicus curiae)
(argued the cause for Petitioners)
(argued the cause for Respondent)
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Facts of the Case 

A group of peanut farmers in Texas threatened to sue Dow Agrosciences in state court for damages caused by one of Dow's herbicides. The farmers alleged Dow violated Texas labeling requirements. Dow asked a federal district court to rule the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) preempted and therefore prohibited the farmers' state law claims. The district court and the Fifth Circuit Court of Appeals ruled FIFRA expressly prohibited additional state labeling requirements such as Texas'.

Question 

Does the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) preempt farmers' state tort claims alleging that Dow's herbicide damaged crops?

Conclusion 
Decision: 7 votes for Bates, 2 vote(s) against
Legal provision: Federal Insecticide, Fungicide, and Rodenticide

No. In a 7-2 opinion delivered by Justice John Paul Stevens, the Court held that the peanut farmers could sue Dow in state court. The Court reasoned that FIFRA preempts only state-law "requirements for labeling or packaging." The peanut farmers' defective manufacture, negligent testing, and breach of warranty claims were based on common-law and did not necessarily require that Dow label or package products in a particular way. The farmers' fraud and negligent-failure to warn claims, by contrast, were based on common-law rules that qualified as "requirements for labeling or packaging." However, FIFRA preempted only state-law labeling requirements" that were "in addition to or different from" FIFRA's labeling standards. The Court sent back to the Fifth Circuit Court of Appeals the question whether Texas law governing fraud and failure-to-warn claims was parallel to FIFRA.

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BATES v. DOW AGROSCIENCES LLC. The Oyez Project at IIT Chicago-Kent College of Law. 18 September 2014. <http://www.oyez.org/cases/2000-2009/2004/2004_03_388>.
BATES v. DOW AGROSCIENCES LLC, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2004/2004_03_388 (last visited September 18, 2014).
"BATES v. DOW AGROSCIENCES LLC," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 18, 2014, http://www.oyez.org/cases/2000-2009/2004/2004_03_388.