Schumacher v. Tyson Fresh Meats, Inc. case brief
434 F.Supp.2d 748
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434 F.Supp.2d 748
CASE SYNOPSIS: Plaintiff
cattle producers initiated a class action lawsuit against defendant
major packers seeking damages for alleged violations of the Packers
and Stockyards Act (PSA), 7 U.S.C.S. §§ 181-229, and for unjust
enrichment in violation of state law. The packers filed a motion for
summary judgment on all claims.
FACTS: The claims arose out of the United States Department of Agriculture's (USDA's) error in publishing boxed beef prices pursuant to the Livestock Mandatory Reporting Act of 1999 (LMRA), 7 U.S.C.S. §§ 1635-1636h, between April 2, 2001, and May 14, 2001. The cattle producers claimed that the packers knowingly used the inaccurate prices to negotiate the purchase of slaughter cattle at prices substantially lower than would have been economically justified had the producers known the accurate higher prices. The packers contended that they were entitled to summary judgment on the producers' PSA claim because the producers could not establish the existence of the element of adverse effect on competition. However, the court held that § 202 of the PSA, 7 U.S.C.S. § 192, did not prohibit only those unfair and deceptive practices which adversely affect competition. The court also rejected the packers' claim that they were entitled to summary judgment on the unjust enrichment claims based upon South Dakota law because none of the slaughter cattle sold during the class period were slaughtered in South Dakota because the place of slaughter did not govern the choice of law.
CONCLUSION: The packers' motion for summary judgment was denied.
FACTS: The claims arose out of the United States Department of Agriculture's (USDA's) error in publishing boxed beef prices pursuant to the Livestock Mandatory Reporting Act of 1999 (LMRA), 7 U.S.C.S. §§ 1635-1636h, between April 2, 2001, and May 14, 2001. The cattle producers claimed that the packers knowingly used the inaccurate prices to negotiate the purchase of slaughter cattle at prices substantially lower than would have been economically justified had the producers known the accurate higher prices. The packers contended that they were entitled to summary judgment on the producers' PSA claim because the producers could not establish the existence of the element of adverse effect on competition. However, the court held that § 202 of the PSA, 7 U.S.C.S. § 192, did not prohibit only those unfair and deceptive practices which adversely affect competition. The court also rejected the packers' claim that they were entitled to summary judgment on the unjust enrichment claims based upon South Dakota law because none of the slaughter cattle sold during the class period were slaughtered in South Dakota because the place of slaughter did not govern the choice of law.
CONCLUSION: The packers' motion for summary judgment was denied.
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