Miller v. Department of Agriculture
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This case involves a dispute between a grain producer, Robert Miller, and the Illinois Department of Agriculture over compensation from the Illinois Grain Insurance Fund. The fund is intended to compensate grain producers for losses incurred when a licensed grain dealer or a licensed warehouseman fails. Miller made a claim with the Department after his grain dealer, SGI Agri-Marketing, LLC, failed before making payment under a “price later contract.”
A key issue in the case was the interpretation of the Grain Code's provision concerning the pricing of grain under a “price later contract.” According to the Code, if such a contract is not signed by all parties within 30 days of the last date of delivery of grain intended to be sold by the contract, then the grain is automatically priced on the next business day after those 30 days, at the market price of the grain at the close of that day.
Miller argued that the grain was priced when he signed a purchase confirmation, which was within the 160-day window before the failure of the dealer, thus entitling him to compensation from the fund. The Department contended that the Grain Code automatically priced the grain as a matter of law on the next business day after 30 days from the last grain delivery, as the parties had not signed a contract agreeing to a pricing formula by then.
The Supreme Court of the State of Illinois agreed with the Department’s interpretation. It held that the statute was unambiguous and provided that the grain would be priced as a matter of law on the next business day after 30 days from the last delivery. Therefore, because the grain was priced outside the 160-day protection window prescribed by the Grain Code, Miller was not eligible for compensation from the fund. The Supreme Court affirmed the circuit court’s judgment and reversed the appellate court's judgment.
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