Law School Case Brief
Horne v. United State Dep't of Agric. - 2009 U.S. Dist. LEXIS 115464 (E.D. Cal. Dec. 9, 2009)
If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.
Defendant, a United States Department of Agriculture (USDA) Judicial Officer (JO), imposed civil penalties and assessments on raisin farmers, including plaintiff Horne, for their alleged violation of various provisions of the Agricultural Marketing Agreement Act of 1937 and the order regulating the Handling of Raisins Produced from Raisin Variety Grapes Grown in California. Plaintiffs filed suit in a federal district court challenging the JO's Feb. 8, 2007 order imposing penalties. The USDA sought summary judgment on the ground that the court did not have jurisdiction to hear the case.
Did the court have jurisdiction to hear the case?
The court held that it only had jurisdiction to review a handler's appeal if that appeal was filed within twenty days. The JO issued its decision on Feb. 4, 2008 and yet plaintiffs initiated their action on Oct. 14, 2008. Accordingly, plaintiffs' untimely challenge was barred by the statute of limitations, and the court did not have jurisdiction to consider it. Because the court lacked jurisdiction over the cause of action, the court dismissed the case, holding that it could not reach the merits of the parties' arguments. Thus, the court granted USDA's summary judgment motion.
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