MEMORANDUM OPINION
FACTUAL BACKGROUND
DONALD J. PORTER, District Judge.
Plaintiffs, residents of Clark and Day Counties in South Dakota, were engaged in farming and livestock operations. In 1976, due to the drought, these counties requested assistance under the Emergency Livestock Feed Program (ELFP), administered by the United States Department of Agriculture (USDA), the Agricultural Stabilization and Conservation Service (ASCS), and the Commodity...
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