Facts: Marsh, the plaintiff (Pl), had an organic farm. Their neighbour, Baxter, the defendant (D), planted genetically-modified (GM) canola on his property. This contaminated the organic farm (due to swaths of GM canola stalks with pods and seeds blown into an area that adjoined their organic farm) and they lost their organic certification and a lot of income. Pl sued D in negligence and nuisance.
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