State v. Quaker Valley Farms, LLC
192 A.3d 996, 235 N.J. 37 (2018)
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Rule of Law:
A landowner of deed-restricted farmland under the New Jersey Farmland Preservation Program may not permanently destroy prime agricultural soil, even when constructing permitted agricultural buildings, because the program's purpose of soil conservation is a co-equal goal with the promotion of agricultural industry.
Facts:
- In 1989, Harold and Rosalie Mathews, owners of a 120-acre farm in Franklin Township known for its high-quality "prime" soil, applied to the State Agriculture Development Committee (SADC) to sell an easement to preserve its agricultural use.
- In 1993, Hunterdon County purchased a deed of easement on the Mathews' farm, which restricted its use solely for agricultural purposes, explicitly prohibiting activities "detrimental to ... soil conservation" while permitting "any new buildings for agricultural purposes."
- In 1997, Quaker Valley Farms, LLC (Quaker Valley) purchased the farm subject to this deed of easement and began operating a wholesale horticultural business, growing chrysanthemums on a twenty-acre field.
- In September 2007, Quaker Valley suffered a significant crop loss due to a hailstorm damaging its exposed chrysanthemum crops.
- To protect future crops, Quaker Valley decided to construct heated hoop houses on the sloped twenty-acre field.
- Quaker Valley then excavated and leveled the twenty-acre field, removing three to twelve feet of soil in some areas, exposing sandstone bedrock, and mixing top-grade topsoil with rocky subsoil.
- Experts determined that these excavation activities permanently damaged the land's prime quality soil, rendering it unfit for a variety of agricultural uses, such as growing row crops.
- Quaker Valley did not approach the Hunterdon County Agriculture Development Board or the SADC for advice or approval regarding the large-scale leveling of the prime soil.
Procedural Posture:
- In February 2008, the State Agriculture Development Committee (SADC) filed a verified complaint in the General Equity Part of the Superior Court (trial court) against Quaker Valley Farms, LLC (Quaker Valley) and David Den Hollander, alleging violations of the deed of easement and the Agriculture Retention and Development Act (ARDA).
- The Superior Court (trial court) granted summary judgment in favor of the SADC, finding Quaker Valley in violation, halting the project, and ordering remediation. The court also dismissed Quaker Valley's civil rights counterclaim.
- Quaker Valley appealed the trial court's decision to the Appellate Division (Quaker Valley as appellant, SADC as appellee).
- The Appellate Division initially affirmed the trial court's grant of summary judgment in favor of the SADC.
- The Appellate Division then granted Quaker Valley's motion for reconsideration, reversed its affirmance of summary judgment for the SADC, and remanded the case to the trial court for further proceedings under a new "practicability" test, while affirming the dismissal of Quaker Valley's civil rights claim.
- The SADC, Hunterdon County, and Franklin Township filed petitions for certification to the Supreme Court of New Jersey, and Quaker Valley filed a cross-petition for certification.
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Issue:
Does a landowner of farmland restricted by an agricultural easement, which permits agricultural buildings but prohibits activities detrimental to soil conservation, violate the easement by excavating and leveling a significant portion of prime soil to erect hoop houses, thereby permanently damaging the land's agricultural productivity?
Opinions:
Majority - Justice Albin
Yes, a landowner of farmland restricted by an agricultural easement, which permits agricultural buildings but prohibits activities detrimental to soil conservation, violates the easement when it excavates and levels a significant portion of prime soil to erect hoop houses, thereby permanently damaging the land's agricultural productivity. The court held that Quaker Valley permanently damaged twenty acres of premier soil, violating its deed of easement and the Agriculture Retention and Development Act (ARDA). The preservation of high-quality soil and open space for future generations is a chief aim of the Farmland Preservation Program. While constructing hoop houses is permissible, permanently damaging prime soil in the process is not. The court rejected the Appellate Division's "practicability" standard, which would subordinate soil conservation to economic feasibility, stating that the ARDA's dual goals of promoting agriculture and preserving farmland are not subordinate to each other but must be balanced. The court concluded that Quaker Valley's activities were so extreme that "no landowner could have reasonably believed that the leveling of a twenty-acre field and destruction of so much prime soil was permissible." The SADC's approval of a C.251 Plan (for storm-water runoff) did not authorize the destruction of prime soil. The court acknowledged the SADC's failure to promulgate clear guidelines but found the violation in this case too egregious to be excused by their absence. The court affirmed the dismissal of Quaker Valley's civil rights claim.
Analysis:
This case clarifies the interpretation of agricultural easements under New Jersey's Farmland Preservation Program, emphasizing that soil conservation is a co-equal goal with promoting agricultural industry, not a subordinate one. It signals to landowners of preserved farms that certain large-scale soil disturbances, even for agricultural structures, are prohibited if they permanently destroy prime soil, regardless of economic benefit. The decision also strongly encourages the State Agriculture Development Committee (SADC) to promulgate clearer guidelines for permissible soil disturbance to provide due process notice to farmers, warning that future enforcement actions without such guidelines may be vulnerable to challenge unless the violation is similarly extreme.
