This court's review of the state review committee's determination is limited by the Agricultural Adjustment Act, 7 U.S.C. § 1281 et seq., to questions of law. See 7 U.S.C. § 1366; McLamb v. Pope, 657 F.2d 77, 78-79 (4th Cir. 1981). The review committee's findings of fact are conclusive if supported by substantial evidence.
On appeal, the Third Circuit found that, in addition to not considering all six Poulis factors, the district court's discussion of two factors was limited and did not set out the basis for its conclusion in such a way to permit meaningful review of its decision. Id. at 97-98 (citing In re MacMeekin, 722 F.2d 32, 35 (3d Cir. 1983) (concluding that the district court's mere description of counsel's conduct as "inexcusable neglect" and "a 'conscious failure to comply' with discovery "does not adequately provide the reviewing court with a rationale for the lower court's decision); Quality Prefabrication, Inc. v. Daniel J. Keating Co., 657 F.2d 77, 80 (3d Cir. 1982) (explaining that there must be some "articulation of the basis for the [district court's] action . . . [to] enable the reviewing court to determine whether the relevant factors were considered and assigned appropriate weight in making the decision")). Accordingly, the appellate court vacated the district court's dismissal order.
The court may only consider questions of law, and findings of fact by the review committee are conclusive, if supported by substantial evidence. See McLamb v. Pope, 657 F.2d 77, 78-79 (4th Cir. 1981). In fact, the evidence in the present case is uncontested. It is only the legal effect of the facts that is at issue.