The Aftermath of CARE v. Cow Palace and the Future of RCRA in CAFO Cases

The industrialization of agricultural practices in the United States has led to significant negative environmental impacts affecting individuals’ use of natural resources such as groundwater. A main contributor to this environmental degradation includes Animal Feeding Operations (“AFOs”) that cluster animals, feed, manure and wastewater, dead animals, and production operations onto a small parcel of land for dairy, cattle, and poultry production operations. This common farming practice can also take place on a larger scale; a Concentrated Animal Feeding Operating (“CAFO”) is an AFO with more than 1000 animals units confined on a facility for more than 45 days during a year. While these operations are considered vital to the nation’s economy, they also entail waste mismanagement and drinking water impacts