Friday, November 1, 2013

Ruckelhaus v. Monsanto Co. case brief

Ruckelhaus v. Monsanto Co. case brief summary
467 U.S. 986 (1984)

Petitioner United States Environmental Protection Agency challenged the judgment of the U.S. District Court for the Eastern District of Missouri, which held that respondent pesticide manufacturer had protectable trade secrets that were taken without just compensation by petitioner for private use and was entitled to compensation.

Respondent pesticide manufacturer applied for a license to sell and distribute various insecticides with petitioner U.S. Environmental Protection Agency. As part of the application process, respondent submitted various data and trade secrets, on which petitioner relied when considering other manufacturer's applications. Petitioner enacted regulations that would make respondent's trade secrets public, and respondent filed suit, arguing that publishing its trade secrets would constitute a "taking," and it was entitled to just compensation.

  • The Court held that trade secrets were property that was protectable under the U.S. Const. amend. V, Taking Clause. 
  • The Court determined, however, that trade secrets were entitled to compensation only when there was a "reasonable investment-backed expectation," and found that only a portion of the data submitted was entitled to protection. 
  • The Court concluded by stating that petitioner was able to file suit under the Tucker Act for compensation, and therefore, refused to order just compensation under the U.S. Const. amend. V, Taking Clause.
The Court reversed the decision of the lower court, and held that respondent was entitled to file suit for compensation under the Tucker Act for only the portion of its trade secrets in which it had a "reasonable investment-backed expectation."

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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