Federal appeals court reverses cattle rancher victory in price manipulation case

[JURIST] The US Court of Appeals for the Eighth Circuit [official website] on Tuesday reversed [opinion, PDF] a controversial trial court judgment in favor of a plaintiff class of cattle ranchers claiming that defendant meat-packing companies underpaid them based on erroneous price data provided by the US Dept. of Agriculture (USDA) [official website]. The class action plaintiffs filed suit under the Packers and Stockyards Act (PSA) [text], alleging that the meat-packing companies knew or should have known that the USDA incorrectly reported the price of select and choice cuts of meat during a six-week period from April 2, 2001, to May 11, 2001. The USDA figures, which determine the prices that meat-packers pay to cattle producers, were underestimated, resulting in lower prices being offered to the plaintiffs. According to the Eighth Circuit, the trial court erred by instructing the jury that the PSA did not require the plaintiffs to show intent to manipulate prices by the defendants. Instead, the court ascertained the legislative intent behind the PSA and ruled that the liability under the PSA requires a showing of intentional manipulation or control over prices:

In the absence of a statutory definition or clear contrary legislative intent, statutory terms are given their plain, ordinary, and commonly understood meaning. This court often turns to a commonly used dictionary to ascertain a word's ordinary meaning. Merriam-Webster's Collegiate Dictionary defines "manipulate" as follows: "to manage or utilize skillfully," or "to control or play upon by artful, unfair, or insidious means esp[ecially] to one's own advantage" or "to change by artful or unfair means so as to serve one's purpose." "Control," according to the same dictionary, means "[t]o exercise restraining or directing influence over," or "to have power over." By using words such as "manage," "artful," "insidious," and "exercise," both definitions suggest that some culpability, such as intent, is required to violate the PSA.
The Eighth Circuit's decision vacates a jury verdict of $9.25 million in favor of the plaintiffs, and remands for a decision for the meat-packing companies, including Cargill Meat Solutions Corporation, Swift Beef Company, and Tyson Fresh Meats, Inc., rather than for a new trial. AP has more.

 

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