MEMORANDUM OPINION
SAMUEL G. WILSON, District Judge.
Plaintiff Arthur K. Davis, a land tenant, filed this action under the Administrative Procedures Act, 5 U.S.C. § 701 et seq., against the Secretary of the United States Department of Agriculture (the "Agency" or "Secretary") challenging its final adverse decision that terminated Davis' contracts under a federal conservation program. Both parties have now moved for summary...
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