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Law School Case Brief

Castillo v. Case Farms of Ohio, Inc. - 96 F. Supp. 2d 578 (W.D. Tex. 1999)

Rule:

Each farm labor contractor, agricultural employer, and agricultural association that employs any migrant agricultural worker shall provide to each worker for each pay period an itemized written statement including information regarding the bases on which the wages are paid, the number of hours worked, the total pay period earnings, the specific sums withheld and the purpose of each sum withheld, and the net pay.

Facts:

Plaintiffs Castillo et. al, a group of migrant farm workers, filed suit against Case Farms of Ohio, Inc. (Case Farms), a chicken processing plant, alleging violations of the Migrant and Seasonal Agricultural Worker Protection Act (AWAP), 29 U.S.C.S. § 1801 et seq., the Fair Labor Standards Act, 29 U.S.C.S. § 201 et seq., and various state laws. The bases for this civil action were the Case Farms’ alleged misrepresentations and mistreatment of Castillo et. al in the recruitment process and the working and living conditions afforded them. Case Farms’ primary defense was that it could not be held legally responsible for the alleged mistreatment. 

Issue:

May an agricultural employer take advantage of migrant workers' diminished bargaining position by enticing them with false promises or subjugating them to unsafe, unsanitary, or unconscionable living and working conditions?

Answer:

No

Conclusion:

The court entered judgment for the farm workers, finding that an agricultural employer may not take advantage of migrant workers' diminished bargaining position by enticing them with false promises or subjugating them to unsafe, unsanitary, or unconscionable living and working conditions. Moreover, Case Farms’ deplorable treatment of the workers in this civil action represented precisely the mistreatment that the AWPA was enacted to prevent and punish. Furthermore, 29 U.S.C.S. § 1821(d)(1) & (2) of the AWPA outlines the specific obligations that an agricultural employer is required to do in its employment.

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