211113P.pdf   09/08/2022  Pitman Farms  v.  Kuehl Poultry, LLC
   U.S. Court of Appeals Case No:  21-1113
   U.S. District Court for the District of Minnesota   
   [PUBLISHED] [Smith, Author, with Gruender and Kobes, Circuit Judges] 
   Civil case - Contracts. In this action plaintiff sought a declaratory 
   judgment that the Minnesota statutes on Parent Company Liability - Minn. 
   Stat. Sec. 17.93 and Minn. Stat. Sec. 27.133 - and the implementing rule - 
   Minn. R. 1572.0040 - do not govern the contracts between chicken farmers 
   and Simply Essentials, Pitman's subsidiary; the district court granted 
   Pitman summary judgment on the ground that the Sec. 17.93 only provides 
   protection to sellers, not producers like the growers, and that neither 
   the statutory sections nor the rule apply when the subsidiary is a limited 
   liability company; the district court erred in failing to consider Sec. 
   27.133 in construing the meaning of the word "seller" in Sec. 17.93 and 
   Rule 1572.00400; considering the provisions together, the court holds the 
   term "seller" can include a "producer" when applying the Producer 
   Protection Act and its implementing Rule; the court holds the use of the 
   phrase "corporation, partnership, or association" in the statutes and rule 
   was intended to include limited liability corporations for the purpose of 
   determining parent-company liability; reversed and remanded for further 
   proceedings.