Riceland Foods v. Bayer Cropscience US, No. 15-2690 (8th Cir. 2016)Annotate this Case
A common-benefit trust fund was established to compensate attorneys leading the MDL concerning Bayer’s LibertyLink LL601 genetically modified rice. On appeal, Bayer and Riceland challenge the district court's order requiring Bayer to cause the deposit of a portion of a settlement between Bayer and Riceland into the fund. Bayer and Riceland argue that because their settlement was the product of negotiations following a state-court judgment, the district court lacked jurisdiction to order Bayer to cause a percentage of the settlement to be deposited into the fund. The court concluded that the district court properly ordered Bayer to hold back a portion of the Bayer-Riceland settlement. In this case, application of the Common Benefit Order was a comparable collateral matter that the district court had jurisdiction to resolve in light of the settlement; the district court properly applied the Common Benefit Order to the settlement and required a percentage of the entire settlement to be redirected to the common-benefit fund; and the district court did not plainly err in assigning to Bayer the duty of causing a deposit of the funds due under the Common Benefit Order. Accordingly, the court affirmed the judgment.