American Cyanamid Co. v. Geye

The question is whether the Federal Insecticide, Fungicide, and Rodenticide Act 1 (“FIFRA”) and its implementing regulations preempt state common-law damage claims for crop damage — specifically, damage to peanut plants. Ordinarily in federal preemption cases, we are asked to decide the scope of preemption, whether congressionally expressed or implied. But in this case, it is not the breadth of preemption, but rather the breadth of the congressionally created exception to express preemption that determines the outcome.

As we explain, Congress has dictated that state actions regarding product…