Eliserio v. Floydada Housing Authority
This case involves a lawsuit brought by individual migrant farm workers and the United Farmworkers of America (UFW) against the Floydada Housing Authority and the United States Department of Agriculture (USDA). Plaintiffs allege that the Floydada Housing Authority operates substandard farm labor housing, violating the Migrant and Seasonal Agricultural Worker Protection Act (AWPA) and the Fair Housing Act (FHA). The Floydada Housing Authority filed a Rule 12(b)(6) motion to dismiss, arguing it's not a 'person' under AWPA, an employment relationship is required for liability, and the UFW lacks standing. The Magistrate Judge recommended denying the motion, finding the Authority is a 'person' under AWPA, no employment relationship is necessary, and the UFW has standing. The District Judge adopted this recommendation, denying the motion to dismiss.