Suit Against ORIL Dismissed After Bankruptcy Court Declines to Pass Judgment on Soundness of Milk Regulatory Scheme In El Farmer, Inc. v.

Suit Against ORIL Dismissed After Bankruptcy Court Declines to Pass Judgment on Soundness of Milk Regulatory Scheme In El Farmer, Inc. v.

Commonwealth of PR, et al., a debtor and its secured creditor initiated an adversary proceeding against Puerto Rico’s Office for Regulation of the Dairy Industry (“ORIL”). The complaint alleged that ORIL injured the debtor by issuing illegal administrative

orders that hurt profits and decreased the value of milk quotas. Chief Judge Cabán Flores, of the Bankruptcy Court for the District of Puerto Rico, invoked the Burford doctrine to abstain from hearing the case. The court held that it is not the appropriate forum to review the soundness of ORIL's policy and that doing so would disrupt the state’s policy with respect to a matter of substantial public concern.