Horne v. Department of Agriculture, 133 S. Ct. 2053

AMAA and California Raisin Marketing Order regulate only ‘handlers’ who process or market raisins; producers are exempt from direct regulation.
Raisin marketers RAC may create reserve pools (reserve-tonnage) and allocate portions of crop to reserve; producers receive limited proceeds from RAC later.
Hornes were raisin producers who arranged Lassen Vineyards to process and market raisins for a fee, avoiding traditional handler role.
USDA enforcement alleged Hornes acted as handlers for 2002–2003 and 2003–2004 crop years, imposing fines, assessments, and reserve-requirement penalties.
Hornes argued they were producers not handlers and raised Fifth Amendment takings defense; ALJ and district court found them handlers; Ninth Circuit affirmed jurisdictional ruling but avoided ruling on takings due to jurisdictional issue.
Supreme Court held the AMAA's remedial scheme withdraws Tucker Act jurisdiction over a handler’s takings claim and that petitioners, as handlers, could raise takings defense in enforcement proceeding and seek review under §608c(14).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ninth Circuit had jurisdiction to hear takings claim	Hornes were producers, not handlers, so takings claim belongs in Court of Federal Claims	Hornes were handlers; monetary penalties arise from enforcement of Marketing Order; Ninth Circuit jurisdiction appropriate	Yes; Ninth Circuit lacked jurisdiction only if petitioners were producers; court must decide where jurisdiction lies (as handlers)
Ripeness and Tucker Act depletion in takings claim	AMAA provides comprehensive remedy; cannot rely on Tucker Act	ripeness bar under Williamson County applies; AMAA remedial scheme withdraws Tucker Act jurisdiction	AMAA withdraws Tucker Act jurisdiction; claim not premature for handlers
Whether takings defense may be raised in enforcement proceeding under §608c(14)	Constitutional defense appropriate in enforcement proceeding	Required to pursue direct challenge under §608c(15); enforcement + fines not permit takings defense	Yes; handlers may raise takings defense in enforcement proceeding; no need to wait for direct challenge
Whether petitioners were properly classified as handlers under the Marketing Order	Petitioners operated as producers and did not engage in handling activities	Petitioners engaged in packing, processing, and other handling activities; subject to order	Petitioners were handlers; subject to the Marketing Order

Williamson County Regional Planning Comm’n v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985) (takings claim not ripe if no final decision or compensation process)
Eastern Enterprises v. Apfel, 524 U.S. 498 (1998) (prematurity and compensation processes in takings claims)
United States v. Ruzicka, 329 U.S. 287 (1946) (administrative challenges to orders must be raised in agency proceedings)
Lucas v. South Carolina Coastal Council, 505 U.S. 1003 (1992) (ripeness/possession considerations in takings)
Fausto v. United States, 484 U.S. 439 (1988) (statutory displacement of Tucker Act jurisdiction by remedial schemes)
Lone v. Detroit Timber & Lumber Co., 200 U.S. 321 (1906) (establishes administrative convenience and non-delegation principles)