By: Guest Author

On May 29, 2025, the U.S. District Court for the Northern District of Iowa ruled that the federal wetlands conservation program known as Swampbuster is constitutional. The decision dismissed a lawsuit filed in 2024 by CTM Holdings, LLC, an Iowa landowner that claimed the program violated both the Commerce Clause and the Fifth Amendment’s Takings Clause. 

Background on Swampbuster 

Swampbuster, part of the Highly Erodible Land and Wetland Conservation program, was created to protect wetlands nationwide by reducing the incentive to convert them into cropland. Under the law, farmers who drain or convert wetlands lose eligibility for certain U.S. Department of Agriculture (USDA) benefits, such as subsidies and conservation payments. The program is administered by USDA’s Natural Resources Conservation Service (NRCS), which determines whether land qualifies as a wetland, converted wetland, or non-wetland.  

The Iowa Case 

CTM Holdings, LLC owns over 1,000 acres of farmland in Iowa, including nine acres designated as a wetland by USDA in 2010, before the company purchased the property. The landowner argued that the designation prevented it from farming the acres and caused lost profits, leaving it with no choice but to forgo farming the land or risk losing USDA benefits. On these grounds, CTM claimed Swampbuster was unconstitutional under both the Commerce Clause and the Takings Clause. 

USDA countered that Swampbuster is a valid exercise of Congress’s spending power, citing earlier rulings that reached the same conclusion. It also argued that the program does not constitute a “taking,” since it does not seize land or require landowners to give up property rights, but instead conditions federal benefits on compliance with conservation rules. 

Conclusion

Ultimately, the Iowa court dismissed CTM’s claims and reaffirmed that Swampbuster is constitutional. This ruling aligns with other recent cases, including a 2021 South Dakota lawsuit, where courts likewise upheld the program under Congress’s spending power.  

To date, courts have consistently declined to strike down Swampbuster, reinforcing its role as a key tool for protecting wetlands while tying conservation compliance to federal farm support. Video overview of this Swampbuster case can be found here: This Wetland Fight Could Go to the Supreme Court | Great Lakes Now 


Categories: Sustainable Agriculture, Wetlands