Department of Agriculture v. Appletree Marketing, LLC

This case requires this Court to determine whether the remedies provided for a breach of the Agricultural Commodities Marketing Act (ACMA) supersede remedies provided by statute under the Revised Judicature Act (RJA) or abrogate those traditionally available at common law. We must further decide whether the member-manager of a limited liability company who causes his business to breach common law and statutory duties may be held independently liable for his personal torts.

We conclude that the ACMA does not provide the exclusive remedy for its violation and thus does not supersede preexisting…