Courts and legislatures around the world have struggled with the increasingly prevalent issue of GM crops. A US judge in December ordered the destruction of a crop [JURIST report] of Monsanto-produced GM sugar beets because of the potentially harmful effect the plants may have on surrounding flora, marking the first time such an order was issued in the US. A week earlier, Germany's Federal Constitutional Court [official website, in German] upheld restrictions on GM crops [JURIST report], including "buffer zones" between GM and conventional crops, after finding that the legislature had acted in the public interest when passing them. The US Supreme Court [official website] ruled [JURIST report] in June 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 GM alfalfa seed, finding that the order did not satisfy the standard four-factor test to determine the availability of injunctive relief.