Texas Natural Resource Conservation Commission Texas Farm, Inc. And Dean Paul D/B/A Paul Farms/Accord Agriculture, Inc. v. Accord Agriculture, Inc./Texas Natural Resource Conservation Commission Texas Farm, Inc. And Dean Paul D/B/A Paul Farms
Accord Agriculture, Inc. (Accord) initiated a lawsuit against the Texas Natural Resource Conservation Commission (TNRCC), challenging the validity of rules established for concentrated animal feeding operations (CAFOs). Accord contended that the TNRCC failed to meet the Administrative Procedure Act's (APA) reasoned justification requirement and exceeded its statutory authority in promulgating these rules. The trial court invalidated the CAFO rules due to the lack of reasoned justification but dismissed Accord's claims regarding a 'takings' violation and the constitutionality of the Right to Farm Act. On appeal, the Court of Appeals affirmed the invalidation of the CAFO rules and the dismissal of the 'takings' claim. However, it reversed the dismissal of Accord's challenge to the Right to Farm Act, remanding that specific issue for further proceedings.