ELR Citation: 55 ELR 20066
No(s). 24-CV-2016-CJW-MAR (N.D. Iowa May 29, 2025) (Williams, J.)

A district court denied summary judgment for a company that owns and manages Iowa farmland in a lawsuit concerning a federal wetland conservation law known as Swampbuster. The company challenged the program, which disqualifies one from receiving USDA farm benefits if they convert certified wetland into crop land, on constitutional grounds. USDA moved for summary judgment, arguing the law was constitutional as a valid exercise of Congress' Spending Clause authority and that it did not constitute a "taking" because compliance was simply a condition on eligibility for voluntary programs. The court found Swampbuster is an exercise of the spending power because Congress chose to provide certain benefits to farmers conditioned upon compliance with its provisions, and that it did not unconstitutionally condition benefits upon the company giving up rights under the Takings Clause because the company "can use its land any way it wants at any time"—the only consequence is a potential loss of certain benefits. It granted summary judgment for USDA.