Specific Field Evidence and Reasoned Credibility Findings Sustain RMA “Good Farming Practices” Denials Under APA Review

1. Introduction

In Miller v. Federal Crop (5th Cir. Jan. 8, 2026) (per curiam, unpublished), Texas farmer Derick Miller challenged the denial of his federal crop insurance claim for 2021 cotton and peanut losses. Miller bought a Federal Crop Insurance Policy under the Federal Crop Insurance Act, 7 U.S.C. § 1501 et seq., through a private provider (Crop Risk Services (CRS)) operating within the FCIC/RMA structure authorized by 7 U.S.C. § 1503.

The core dispute was whether Miller’s losses were excluded because he failed to follow “good farming practices” (GFP)—a statutory and policy limitation that precludes coverage where losses stem from farming practices that do not meet generally recognized standards for the area. The agency (FCIC/RMA/USDA) determined Miller’s weed control and peanut irrigation practices (and related agronomic choices such as seeding rates/rotation) did not meet GFP, and denied the claim. Miller sought declaratory and injunctive relief, contending the GFP determination was procedurally defective and unsupported by evidence, particularly because the agency allegedly discounted his experts (a county extension agent and an agronomist).

2. Summary of the Opinion

The Fifth Circuit affirmed the district court’s summary judgment for the agency. Applying APA review, the court held the record supported the agency’s GFP determination and that the agency articulated a rational basis for crediting “specific observational and photographic evidence” and expert support obtained by RMA/CRS over the more general statements offered by Miller’s experts. The court rejected Miller’s claim that the agency “refused” to consider his experts, emphasizing that the determination expressly acknowledged contrary opinions and explained why it found them less credible.

3. Analysis

A. Precedents Cited

Dediol v. Best Chevrolet, 665 F.3d 435 (5th Cir. 2011)
Used for the standard of review on appeal from summary judgment: de novo review, viewing evidence in the light most favorable to the nonmovant and drawing reasonable inferences in that party’s favor. This framed the court’s posture as reviewing the district court’s judgment anew while still applying APA constraints to the merits.
Crawford v. Formosa Plastics Corp., 234 F.3d 899 (5th Cir. 2000) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986))
These authorities supply the familiar Rule 56 formulation: summary judgment is proper when there is no genuine dispute of material fact, and a dispute is “genuine” only if a reasonable factfinder could return a verdict for the nonmovant. In this case, those standards mattered because Miller attempted to cast competing expert views as a fact dispute; the court treated the dispute as one about whether the agency’s decision was reasonable on the administrative record, not a freewheeling trial-level credibility contest.
Shell Offshore Inc. v. Babbitt, 238 F.3d 622 (5th Cir. 2001)
Provided the governing APA standard: whether the agency action was “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law,” echoing 5 U.S.C. § 706(2)(A). This is the doctrinal anchor for reviewing the GFP determination.
Hayward v. United States Dep't of Labor, 536 F.3d 376 (5th Cir. 2008)
Cited for two central APA principles: (1) the court looks for a “rational connection between the facts found and the decision made,” and (2) the agency’s action “must be upheld, if at all, on the basis articulated by the agency itself.” This directly informed the court’s focus on what the “Good Farming Practices Determination for Derick Miller” said, and whether it explained its weighing of competing opinions.

B. Legal Reasoning

The statutory/policy exclusion controlled the dispute.
Federal crop insurance excludes losses caused by failure to follow GFP. The panel cited 7 U.S.C. § 1508(a)(3)(A)(iii) and the policy’s GFP definition in 7 C.F.R. § 457.8. It also noted RMA’s authority to make GFP determinations under 7 U.S.C. § 1508(a)(3)(B). That allocation of authority framed Miller’s challenge as an APA review of an expert, technical agency decision rather than a de novo agronomy dispute.
The agency built a record tied to concrete field conditions.
The determination referenced provider “observational, photographic, and biomass imaging evidence” of weed infestation competing with crops for moisture and nutrients, plus timing concerns (post-emergence chemical/mechanical controls applied “too late”). For peanuts, it also cited irrigation issues at “critical” times, a below-recommended seeding rate (47,000 seeds/acre versus 73,000–87,000 recommended), and a rotation concern (contradicting the Texas Peanut Production Guide). The panel emphasized these specifics because APA review turns on whether the agency’s stated reasons connect to the evidence it identified.
Competing expert opinions did not, by themselves, make the determination arbitrary.
Miller argued the agency “summarily dismissed” his experts (Geoff Cooper and Dr. Justin Tuggle) in favor of Mark Scott. The court rejected that framing because the agency expressly acknowledged the contradictory opinions and articulated why it found Miller’s experts less credible—contrasting their “general nature” with specific photographic/observational evidence and citing Texas AgriLife material (“Weed Management in Texas Cotton”) to undercut at least one asserted expert conclusion. Under Hayward, what mattered was that the agency explained its credibility assessment and grounded it in the record it cited.
Alleged procedural defects failed because the record showed consideration, not refusal.
Miller argued that FCIC procedures and regulations required evaluation of “relevant factors” when expert opinions conflict, including whether area farmers used similar practices. The panel concluded the record did not support a claim that the agency ignored required factors or refused to consider Miller’s evidence. Importantly, the court treated Miller’s challenge as asking it to reweigh credibility without showing the agency’s cited evidence was wrong (e.g., no claim the photos were manipulated or factually erroneous).
APA review limited the court’s role.
The panel repeatedly returned to the APA’s core restraint: the reviewing court does not decide which agronomic view it prefers; it asks whether the agency offered a reasoned explanation supported by the administrative record. Because the determination connected specific evidence to specific GFP deficiencies, the court found no arbitrariness.

C. Impact

Although the opinion is “not designated for publication” (and thus is not binding precedent under Fifth Circuit rules), it is still instructive in GFP/APA disputes and likely to be cited for its practical approach:

Deference to RMA on technical GFP calls: Where RMA identifies concrete field evidence (photos, inspections, imaging) and ties it to GFP standards, courts will be reluctant to disturb the determination.
What “competing experts” must look like to matter: Producers challenging GFP denials should expect that generalized letters will be less persuasive than site-specific rebuttals that confront the agency’s cited evidence (e.g., addressing particular photos, dates, weed pressure severity, irrigation logs, planting conditions, and localized recommendations).
Reasoned explanation is the key procedural safeguard: The case underscores that agencies may choose among experts if they (a) acknowledge contrary opinions and (b) explain why they credited one set of inputs over another with reference to the record.

4. Complex Concepts Simplified

Federal crop insurance structure (FCIC/RMA/provider): Private companies sell and service policies, but the policies are federally written/reinsured and administered within USDA’s FCIC/RMA framework. Disputes about determinations like GFP can become federal administrative-law cases.
Good Farming Practices (GFP): Not “best practices,” but generally recognized methods for the area that allow the crop to make normal progress and produce at least the insured yield benchmark. If losses are caused by failing GFP, coverage can be denied.
APH yield: “Actual Production History” is a yield measure used to set a production guarantee and thus insurance coverage. References to whether appraisals support meeting APH are shorthand for whether the crop’s condition is consistent with expected insured yields.
APA “arbitrary and capricious” review: The court does not decide the issue from scratch. It checks whether the agency considered the matter reasonably and explained its decision with a logical link to evidence in the record.
Summary judgment in APA cases: Unlike ordinary civil cases where factual disputes go to a jury, APA cases often turn on the administrative record; “summary judgment” effectively resolves whether the record supports the agency under the APA standard.

5. Conclusion

Miller reinforces that GFP determinations—when supported by specific inspections, photographs/imaging, and articulated agronomic benchmarks— will generally survive APA review even in the face of contrary producer-retained expert opinions. The decisive feature was not the mere presence of competing experts, but the agency’s documented, record-based explanation for why it credited one set of evidence over another. In practical terms, the opinion signals that successful challenges to GFP denials must directly rebut the agency’s cited field-specific proof and show a true failure of reasoning or procedure, not simply a disagreement over agronomy.