The U.S. Supreme Court case Asgrow Seed Company v. Winterboer, 1994, revolved around the interpretation of a provision in the Plant Variety Protection Act (PVPA). The PVPA allows farmers to save seeds from their crops for replanting on their own farms but prohibits them from selling such saved seeds to others for planting purposes. However, an exception was made where sales were "brown bag" or incidental to the sale of other farm products. Asgrow Seed Co., a developer and seller of hybrid corn seed varieties sued Denny and Becky Winterboer who sold saved seeds as part of their farming operation under this exception clause. Asgrow argued that this practice violated its rights under the PVPA while Winterboers contended they were within legal limits set by Congress in allowing some seed saving and sales among farmers. The Supreme Court ruled in favor of Asgrow stating that "brown bag" sales could only be made as truly incidental to typical crop sales rather than being a regular business activity.

In the dissenting opinion for ASGROW SEED COMPANY v. DENNY WINTERBOER AND BECKY WINTERBOER, Justice Stevens argued that the majority's interpretation of the Plant Variety Protection Act (PVPA) was incorrect and overly restrictive. He contended that Congress intended to allow farmers to sell saved seed as a part of their normal farming operations, including sales to other farmers for reproductive purposes. The majority’s decision limited this right by interpreting “saved seed” in a narrow way and restricting farmer-to-farmer sales only for crop production but not further reproduction. According to Justice Stevens, such an interpretation contradicted both the language and purpose of PVPA which aimed at balancing interests between plant breeders who needed incentives through protection rights and farmers who traditionally reused or sold seeds from their harvests.