Maple Drive Farms Ltd. Partnership v. Vilsack

OPINION

BOGGS, Circuit Judge.

The “Swampbuster” provisions of the Food Security Act of 1985 deny certain farm-program benefits to persons who convert a Wetland on their property for agricultural purposes. Nicholas H. Smith challenges the United States Department of Agriculture’s determination that Smith had converted 2.24 acres of wetland on his property and that he is, consequently, totally ineligible for program benefits. Specifically, Smith contends that the Department erred when it failed to: (1) analyze whether his purported conversion would have only a minimal effect on surrounding…