## Facts

- The Federal Crop Insurance Corporation (FCIC), a federal agency within the Department of Agriculture, insured wheat producers under terms set by statute and FCIC regulations.
- FCIC issued Wheat Crop Insurance Regulations that were published in the Federal Register in February 1945.
- The regulations excluded from coverage “spring wheat which has been reseeded on winter wheat acreage.”
- Idaho wheat farmers applied for insurance through a local agricultural committee acting as FCIC’s agent and disclosed that 400 of 460 acres would be reseeded spring wheat on winter-wheat acreage.
- The local committee advised that the entire crop was insurable and recommended acceptance; the formal application did not reveal that part of the crop was reseeded, and FCIC later accepted the application.
- After drought destroyed most of the crop, FCIC discovered the reseeded acreage and denied payment for that portion.
- The farmers lacked actual knowledge of the regulatory exclusion and relied on the agent’s assurance.
- A jury verdict for the farmers was affirmed by the Idaho Supreme Court; the U.S. Supreme Court granted review.

## Issues

1. Whether FCIC is liable for losses on reseeded spring wheat acreage when published regulations expressly exclude such acreage from coverage.
2. Whether lack of actual knowledge of the exclusion permits recovery despite Federal Register publication.
3. Whether FCIC is bound or estopped by its local agent’s erroneous assurance that the excluded crop was insurable.

## Decision

- The Supreme Court reversed the Idaho Supreme Court and held FCIC was not liable for losses on the reseeded acreage.
- The Court held that regulations duly published in the Federal Register provide legal notice and bind those seeking benefits under the program, regardless of actual knowledge.
- The Court rejected estoppel based on the agent’s misstatements because the agent lacked authority to confer coverage contrary to the published regulations.

## Legal Principles

- Publication of agency rules and regulations in the Federal Register constitutes legal notice of their contents.
- Persons dealing with the federal government are charged with knowledge of duly published statutory and regulatory limits on an agency’s authority.
- The government is not bound by unauthorized representations of its agents that conflict with governing statutes or published regulations.
- Courts will not enforce arrangements that would require the government to provide benefits or assume obligations it lacked legal power to undertake under controlling regulations.

## Conclusion

Because the published FCIC regulations excluded insurance for spring wheat reseeded on winter-wheat acreage, the farmers could not recover for losses on the reseeded portion despite their lack of actual knowledge and their reliance on contrary advice from a local agent.


Fed. Crop Ins. Corp. v. Merrill, 332 U.S. 380 (1947)