Of all the things I find upsetting about the U.S. Food and Drug Administration’s case against Pennyslvania farmer Dan Allgyer (and there are many), the most upsetting is the agency’s admission that its agents entered private residences to pick up their milk.

They didn’t even go onto the property under their own names, but under aliases. And they didn’t just do it once or twice, but “placed orders for unpasteurized cow milk on 23 occasions,” according to the filing in Pennsylvania District Court seeking a permanent injunction against Allgyer.

The way food clubs like that in Maryland work, various members offer their homes as drop sites. Food orders are packed at the farm, and shipped via a delivery truck that leaves it off according to where members designate they want to pick it up. Members may have a refrigerator in the garage or coolers on the deck where members come to pick up their orders.

It’s testimony to just how private these arrangements are that food can only be obtained at another member’s home. There’s nothing even vaguely approaching a retail sale open to the public.

In any event, if you figure FDA agents made pickups at six different residences over the year-plus of the investigation, then they likely entered a half dozen residences perhaps four times.
How would you like undercover FDA agents on your property? Probably not too much, on even one occasion. But four different times?

And what were the agents doing while on private property? I just wrote an article for Grist in which I speculated about the possibilities. (Last time I looked, it was the second most read article on the site.)

What intrigues me as well is the question of whether FDA agents violated the U.S. Constitution’s Fourth Amendment. Just to refresh your memory, here’s what it says: “The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.”

It seems clear that the FDA didn’t have search warrants to enter the residential properties they picked up their milk at. But did they need warrants? An FDA official refused to respond to my question on this matter.

But I’ve since been in touch with four lawyers and a law enforcement agent about this question, and they are divided. Two lawyers tell me they think the FDA might have gone too far without establishing “probable cause” in advance with a judge. Two other lawyers, along with the law enforcement agent, tell me that likely the FDA has legal precedent on its side. The main example they use is undercover drug investigations. In those cases, the law enforcement agent tells me, undercover agents are presumed to have been “invited” into residences to obtain drugs. The same could well hold in the case of the raw milk investigation–by virtue of joining a buying club, the FDA agents were then “invited” to obtain their milk, he says.

Perhaps this question will play out in a courtroom discussion. It could be that illegal drugs like heroin and cocaine are in a somewhat different investigative category than raw milk, with different investigative requirements. In other words, if you’re going to sneak onto someone’s property to obtain raw milk, you better have an awfully good explanation, made in advance.

In the meantime, “The right of the people to be secure in their persons, houses…” has a pretty hollow ring to it, knowing that FDA agents can just come slinking around your house looking for food they don’t approve of. ?

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The Maryland food club now has a Facebook page along with a page for donations to support its legal fund. And I can’t figure out if the FDA Facebook page is the agency’s official site, but it sure is filled with decidedly unfriendly commentary from foodies.

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Finally, Saturday is the Third Annual Raw Milk Symposium, being held in Minneapolis. Canadian farmer Michael Schmidt is the keynote speaker, among a cast of many experts.