Riceland Foods v. Bayer Cropscience US, No. 15-2690 (8th Cir. 2016)
Annotate this CaseA 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.
Court Description: Colloton, Author, with Shepherd, Circuit Judge, and Bough, District Judge] Civil case - Class Actions. For the court's prior opinion in the matter see In re Genetically Modified Rice Litigation, 764 F.3d 864 (8th Cir. 2014). While the court held in the prior opinion that the district court properly concluded that it lacked jurisdiction to apply its Common-Benefit Order to state-court only plaintiffs, that case does not control here, because both Riceland and Bayer were parties to multiple federal lawsuits before the district court at the time of settlement, and the court had jurisdiction to enter orders regarding Riceland's settlement of its claims against Bayer; the district court did not abuse its discretion in the amount of the allocation it ordered paid into the Common-Benefit Fund from the Riceland-Bayer settlement; the court did not err in assigning to Bayer the duty of causing a deposit of the funds due under the Common-Benefit Order.
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