Courts and legislatures around the world have struggled with the increasingly prevalent issue of GM crops. In June, the US Supreme Court [official website] ruled [opinion, PDF; JURIST report] in Monsanto Company v. Geerston Seed Farms [Cornell LII backgrounder] that a trial court abused its discretion when it issued a nationwide injunction against a genetically modified alfalfa seed. The trial court sought to remedy a National Environmental Policy Act (NEPA) [EPA materials] violation based on only a remote possibility of reparable harm. The US Court of Appeals for the Ninth Circuit held [opinion, PDF] that NEPA plaintiffs are specially exempt from the requirement of showing a likelihood of irreparable harm to obtain an injunction, affirming the nationwide injunction. Justice Samuel Alito, writing the opinion of the court, reversed the circuit court's ruling, stating that NEPA violations, absent unusual circumstances, are not exempt from the standard four-factor test to determine the availability of injunctive relief.