February 26, 2018 En Banc, Ninth Circuit Holds: Only ‘True Sales’ of Receivables Comply with PACA Ninth Circuit reverses its own precedent and eliminates a circuit split by favoring farmers. 9th Circuit , March 2, 2017 PACA Circuit Split Heading for En Banc Rehearing or Certiorari Petition Two judges urge Ninth Circuit to overrule precedent and line up with other circuits. 9th Circuit ,