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Mart v. Mart

824 N.W.2d 535 (2012)

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Mart v. Mart

Court of Appeals of Iowa

824 N.W.2d 535 (2012)

Facts

Mike Mart (defendant) leased a farm from his father. Under the terms of the 20-year lease, Mike paid his father $85 per tillable acre each year. 8.7 acres of the farm was designated wetlands by the federal government under the Swampbuster provisions of the Food Security Act of 1985 (16 U.S.C. §§ 3801, 3821-3824) (Swampbuster Act). After Mike’s father died, the ownership of the farm passed equally to Mike and his three siblings, Dennis, Thomas, and Cheryl Mart (the Mart siblings) (plaintiffs). Ten years into the lease, Mike planted corn on the 8.7 acres of wetlands. The federal government penalized the farm’s owners for Mike’s actions by denying them $152,000 in federal benefits. The Mart siblings appealed this penalty by claiming that they were unaware of Mike’s breach of the Swampbuster Act. They won their appeal and received the benefits they had been denied. The next year, Mike restored the 8.7 acres to wetlands. The Mart siblings sought to cancel Mike’s lease on the farm, later filing a petition for forcible entry and detainer against Mike. The trial court held that Mike’s violation of the Swampbuster Act did not constitute a breach of his farm lease. The Mart siblings appealed.

Rule of Law

Issue

Holding and Reasoning (Danilson, J.)

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