In May 2014, the Supreme Court of the Australian state of Western Australia dismissed "Marsh v. Baxter". The plaintiff was Steve Marsh, an organic farmer, and the defendant was Michael Baxter, his lifelong neighbour, who grew GM canola. In late 2010, Marsh found seeds from Baxter's crop in his fields. Later, Marsh found escaped GM canola growing amidst his crop. Marsh reported the seed and plants to his local organic certification board, and lost the organic certification of some 70 per cent of his 478 hectare farm. Marsh sued on the grounds that Baxter used a method of harvesting his crop that was substandard and negligent, and on the basis that his land had been widely contaminated. In its summary judgment, the court found that approximately 245 cut canola plants were blown by the wind into Marsh's property, Eagle's Rest. However, Baxter's method (swathing) was "orthodox and well accepted harvest methodology". "In 2011, eight GM canola plants were found to have grown up as self-sown volunteer plants on Eagle Rest", which "were identified and pulled out", and "no more volunteer RR canola plants grew on Eagle Rest in subsequent years". The summary judgment stated that the loss of organic certification "was occasioned by the erroneous application of governing NASAA Standards applicable to NASAA organic operators as regards GMOs (genetically modified organisms) at the time". and that "he absence of a reliable underlying evidentiary platform to support a perpetual injunction against swathing was a significant deficiency".