Texas peanut farmers allege that their crops were severely damaged by the application of Dow's "Strongarm" pesticide, which the Environmental Protection Agency (EPA) registered pursuant to its authority under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

Petitioners gave Dow notice of their intent to sue, claiming that Strongarm’s label recommended its use in all peanut-growing areas when Dow knew or should have known that it would stunt the growth of peanuts in their soil. In response, Dow sought a declaratory judgment in the Federal District Court, asserting that FIFRA pre-empted petitioners’ claims. Petitioners counterclaimed, raising several state-law claims sounding in strict liability, negligence, fraud, and breach of express warranty. The District Court rejected one claim on state-law grounds and found the others barred by FIFRA’s pre-emption provision, 7 U. S. C. §136v(b).

The legal concept of federal pre-emption means that federal law and regulation takes the place of state law. FIFRA authorizes states to regulate the sale and use of federally registered pesticides. However, with regard to labelling, FIFRA rules take precedence over state laws. States may not,, impose "labeling or packaging requirements in addition to or different from those required by [FIFRA]". 7 U.S.C. § 136v(b). Besides, the FIRFA’s pre-emption exists since the case law Cipollone v. Loggett Group, Inc 505 US 504.

The Supreme Court has to decide if the article 136 v(b) expressly overrides state law claims. In other words, is the jury's verdict that the peanut growers' damages resulted from a labeling defect to be considered a "requirement" for the pesticide manufacturer to change the product's label, contrary to FIRFRA preemption?

According to the Court, the judgment of a jury is not equivalent to a requirement but only an event: a requirement is a rule of law that must be obeyed; an event, such as a jury verdict, that merely motives an optional decision is not a requirement. Federal laws are understood to be "parallel requirements" to FIFRA, and preemption does not apply to them.

Especially given that FIFRA does not provide a federal remedy to those injured as a result of a manufacturer’s violation of FIFRA’s labeling requirements, nothing in §136v(b) precludes States from providing such a remedy.

Dow’s contrary reading of §136v(b) fails to make sense of the phrase “in addition to or different from.” Even if Dow offered a plausible alternative reading of §136v(b), the Court “would have a duty to accept the reading disfavoring pre-emption”. The Court adds that the long history of tort litigation against manufacturers of poisonous substances adds force to the presumption against pre-emption.

According to the H. Bishop Dansby, the real importance of Bates is that it marks the end of the use of pre-emption for tort reform. This case not only clears the way for protection against pesticides, but also deals a lethal blow to tort reform through the back door of federal pre-emption, returning the civil litigation system to its traditional role of responding to societal needs. Pesticide companies enjoy no more relative immunity from tort liability.