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Buchanan v. Simplot Feeders Limited Partnership

Washington Supreme Court
952 P.2d 610 (1998)


Facts

The Buchanans (plaintiffs) owned property. Simplot Feeders Limited Partnership (defendant) purchased neighboring land and began operating a feedlot and meat processing plant. The Buchanans filed suit for nuisance based on the odors emanating from Simplot’s land. Simplot claimed that it was exempt from nuisance suits based on the federal right-to-farm statute. A 1992 amendment to the statute stated that the statute was not meant to impair a property owner’s right to sue for damages. The Buchanans asserted that the amendment changed the statute to exempt farms only from nuisance suits seeking injunctive relief. Simplot argued that the language in the amendment referred only to a plaintiff’s right to pursue other, non-nuisance claims, such as trespass. The federal district court certified the question of the amendment’s effect to the Washington Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Dolliver, J.)

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