Buchanan v. Simplot Feeders Limited Partnership

The Buchanans (plaintiffs) owned property before Simplot Feeders (defendant) purchased neighboring land and began operating a feedlot and meat processing plant; the Buchanans sued for nuisance over odors from Simplot's operation, and Simplot claimed exemption under a right-to-farm statute. A disputed 1992 amendment stated the statute wasn't meant to impair a property owner's right to sue for damages, and the parties disagreed whether this amendment limited the farm exemption only to suits seeking injunctions (Buchanans' view) or merely preserved unrelated non-nuisance claims like trespass (Simplot's view); the federal district court certified the amendment's meaning to the Washington Supreme Court.

Whether a right-to-farm statute exempts agricultural activities from nuisance suits when those activities existed before the nonagricultural use the plaintiff complains about, or whether it can also protect agricultural activities that came after a preexisting nonagricultural neighbor.