John Deere Financial, f.s.b. v. Bio-Mass Renewable Technologies, Inc., 0:15-cv-00031

John Deere Financial provided farm-plan credit accounts to Jeffrey and Holly Littrell pursuant to written Farm Plan Agreements; the Littrells accepted terms by authorized account use.
In April–May 2013, the Littrells charged nearly $450,000 of inventory through Bio-Mass Renewable Technologies (BRT) using their farm-plan accounts and did not pay the charges.
John Deere sued BRT, Jeffrey Littrell, Holly Littrell, and Jeff Buresh; John Deere moved for summary judgment against the Littrells on breach of contract for unpaid account charges.
John Deere sought joint-and-several liability for the unpaid charges; the Farm Plan Agreements contained a co-applicant joint-and-several clause, but each Littrell signed only a separate application.
John Deere presented account statements and affidavits showing unpaid balances and the Littrells’ acknowledgment of their accounts; the Littrells denied agreement to the contracts and argued BRT — not they — incurred the charges.
The court found the Littrells breached their respective Farm Plan Agreements but declined to impose joint-and-several liability because damages were divisible and co-applicant status was not established.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Littrells breached Farm Plan Agreements	Littrells agreed to pay all charges; they used accounts and failed to pay	Deny they agreed to the contracts; contend BRT incurred charges	Breach: court grants summary judgment for John Deere — Littrells breached by not paying charges
Whether Littrells ever agreed to the Farm Plan Agreements	Account use and financial disclosures show acceptance/acknowledgment	Bare denials; no evidentiary support that they never agreed	Court rejects litigants’ unsupported denials; acceptance shown by account use and records
Whether charges were BRT’s liability rather than Littrells’	Agreements obligate account holder to pay charges regardless who posted them	Argue BRT charged accounts, not them	Court holds Littrells contracted to pay all amounts charged to their accounts; liability stands
Whether Littrells are jointly and severally liable	Seek joint-and-several recovery under agreement or in absence of co-applicant clause	Littrells point to separate applications; deny co-applicant status; argue damages divisible	Court finds no evidence they were co-applicants and damages are divisible; denies joint-and-several liability; orders plaintiff to propose allocation between accounts

Weitz Co., LLC v. Lloyd’s of London, 574 F.3d 885 (8th Cir. 2009) (summary-judgment evidence must be viewed in light most favorable to nonmoving party)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment is integral to Rules and movant bears burden to show no genuine issue)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (nonmoving party cannot rely on mere allegations; must set forth specific facts creating a genuine issue)
Watkins Inc. v. Chilkoot Distrib., Inc., 719 F.3d 987 (8th Cir. 2013) (elements of breach of contract claim)
Park Nicollet Clinic v. Hamann, 808 N.W.2d 828 (Minn. 2011) (state law on contract-formation and breach elements)
Duluth Superior Erection, Inc. v. Concrete Restorers, Inc., 665 N.W.2d 528 (Minn. Ct. App. 2003) (when separate breaches may give rise to joint-and-several liability only if damages are indivisible)