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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Castillo v. Case Farms of Ohio, Inc.

A group of migrant farm workers filed a civil action against Case Farms of Ohio, claiming violations of the Migrant and Seasonal Agricultural Worker Protection Act (AWPA), the Fair Labor Standards Act (FLSA), and state laws. The plaintiffs, recruited from Texas to work in Ohio, alleged misrepresentations regarding employment terms, transportation, and housing conditions. The court found Case Farms liable for numerous AWPA violations, including using an unregistered farm labor contractor, failing to provide written disclosures, providing false information, violating working arrangement terms, failing to comply with housing health and safety codes, and failing to ensure vehicle insurance and inspection for the 1996 plaintiffs. Some 1997 plaintiffs also proved violations related to written disclosures and housing occupancy terms. The court awarded statutory and actual damages to different groups of plaintiffs for these violations, while rejecting most FLSA and state law claims due to insufficient evidence or lack of agency.

Migrant workers' rightsAgricultural employmentWorker Protection ActFair Labor Standards ActWage and hour violationsUnregistered labor contractorSubstandard housingUnsafe transportationFalse promisesJoint employer doctrine
References
71
Case No. MISSING
Regular Panel Decision

Marshall v. Presidio Valley Farms, Inc.

The Secretary of Labor initiated legal action against Presidio Valley Farms, Inc. and Bill Bishop for alleged violations of the Fair Labor Standards Act concerning underpaid farm workers. The defendants contended the workers were employed by independent contractor crew leaders, but the court determined the crew leaders were, in economic reality, employees of the defendants. Consequently, the defendants were held responsible for the minimum wage violations from 1975 to 1977 and for deliberately falsifying wage records. The court issued a permanent injunction to prevent future violations and ordered the defendants to pay a total of $85,248 in back wages, plus prejudgment interest, to the identified and unidentified underpaid employees.

Fair Labor Standards ActMinimum WageFarm WorkersIndependent ContractorsEmployee MisclassificationWillful ViolationInjunctionBack WagesAgricultural LaborWage and Hour
References
20
Case No. 21-0676
Regular Panel Decision
Jun 07, 2024

Steve Huynh, Individually Yvonne Huynh, Individually Huynh Poultry Farm, LLC D/B/A Steve Thi Huynh Poultry Farm D/B/A Huynh Poultry Farm T & N Poultry Farm, LLC Thinh Bao Nguyen, Individually Timmy Huynh Poultry Farm Timmy Huynh, Individually And Sanderson Farms, Inc. v. Frank Blanchard, Angelia Snow, Tanya Berry, Kimberly Riley, John Miller, Amy Miller, Chad Martinez, Emily Martinez, Mersini Blanchard, Malakoff Properties, LLC, and Ronny Snow

This case originated from a nuisance suit brought by neighbors against two large poultry farms in Henderson County, Texas, operated by the Huynh family and Sanderson Farms, Inc. The neighbors alleged persistent, offensive odors constituting a nuisance. A jury initially found a temporary nuisance, leading the trial court to issue a permanent injunction that effectively shut down the farms. The Supreme Court of Texas affirmed the entitlement to permanent injunctive relief, agreeing that harm was imminent and legal remedies inadequate. However, it reversed the trial court's injunction in part, finding it overly broad for completely halting operations and imposing a wide geographic ban, and remanded the case for a more tailored injunction.

Nuisance LawPoultry FarmingEnvironmental RegulationsInjunctive ReliefProperty RightsOdor NuisanceTemporary NuisancePermanent NuisanceBalancing EquitiesJudicial Discretion
References
108
Case No. 2024 NY Slip Op 01944 [226 AD3d 836]
Regular Panel Decision
Apr 10, 2024

Ragusa v. Drazie's Farm II, LLC

The plaintiff, Matthew Ragusa, appealed an order denying his cross-motion to amend the complaint to add Drazie's Farm, LLC as a defendant and granting summary judgment to Drazie's Farm II, LLC on a Labor Law § 240 (1) claim. The Appellate Division, Second Department, affirmed the lower court's decision. The court found that the relation-back doctrine did not apply because Drazie's Farm II, LLC and Drazie's Farm, LLC were separate entities with potentially different defenses, thus not united in interest. Furthermore, Drazie's Farm II, LLC established that it did not own the property where the accident occurred and therefore could not be held liable under Labor Law § 240 (1).

Personal injuryLabor Law § 240 (1)A-frame ladderfall from heightpremises liabilityrelation-back doctrinesummary judgmentlimited liability companyproperty ownershipadjoining properties
References
10
Case No. 13-15-00098-CV
Regular Panel Decision
Jun 04, 2015

Hudson Insurance Company v. Bruce Gamble Farms, Jim Gamble Farms, Brian Jones Farms, & Crop Guard Group, Inc.

The case involves an appeal regarding a trial court's denial of Hudson Insurance Company's motion to compel arbitration. Plaintiffs, Bruce Gamble Farms, Jim Gamble Farms, and Brian Jones Farms, sued Hudson and CropGuard Group, Inc., alleging overcharged crop insurance premiums for Crop Year 2013. The appellees argue that a valid and conscionable arbitration agreement did not exist, citing non-receipt of the policy, unconscionable terms like a shortened statute of limitations, and the dispute falling outside the arbitration clause's scope as it pertains to policy or procedure interpretation rather than claims for loss. The brief advocates for upholding the trial court's decision.

Crop InsuranceArbitrationContract DisputeUnconscionabilityAppellate ReviewInsurance PremiumsTexas LawFederal Arbitration ActMotion to CompelCivil Procedure
References
36
Case No. MISSING
Regular Panel Decision

Southern Farm Bureau Casualty Insurance Co. v. Bohls

Southern Farm Bureau Casualty Insurance Company initiated a declaratory judgment suit to ascertain the coverage of an automobile liability insurance policy issued to Jesse G. Bohls, specifically concerning claims by farm laborers injured in an August 10, 1955 accident. The core issue revolved around an exclusion clause for employee injuries, which the Texas Board of Insurance Commissioners had revised. The Court had to determine if the farm laborers, Dorothy Isaac and Roxie Burr, were 'engaged in the employment' of Bohls at the time of the accident, as they were being transported home after work. Citing previous judicial interpretations, the court concluded that the laborers were not actively performing services for Bohls during their transportation. Consequently, the insurance policy was found to provide coverage for their claims, affirming the Trial Court's judgment in favor of the defendants.

Automobile liability insuranceInsurance policy coverageFarm laborersEmployee exclusion clauseDeclaratory judgmentScope of employmentTransportation of employeesWorkers' compensation lawTexas insurance lawInterpretation of insurance policy
References
5
Case No. No. 10-12-00197-CV
Regular Panel Decision
Sep 05, 2013

Brian Dunn, Janel Dunn and Leisel Moseley v. Happy Hill Farm Academy/Home and Happy Hill Farm Children's Home Endowment Fund, Happy Hill Farm Children Home, Inc., A/K/A Dallas Cowboys Courage House

Appellants Leisel Moseley, Brian Dunn, and Janel Dunn appealed a summary judgment favoring Happy Hill Farm Academy/Home and related entities. They claimed wrongful termination, alleging Happy Hill Farm operates as a treatment or mental-health facility under the Texas Health and Safety Code, and contested the applicability of statutory exemptions. The court affirmed the summary judgment, ruling that Happy Hill Farm is neither a treatment nor a mental-health facility, but a basic child care facility with a school. Furthermore, the court found Happy Hill Farm exempt from former Chapter 242 of the Texas Health and Safety Code, as it operates under the jurisdiction of the Texas Department of Family and Protective Services, a recognized state agency.

Summary judgmentWrongful terminationTexas Health and Safety CodeMental health facilityTreatment facilityBoarding schoolState agency exemptionEmployment at willRetaliatory dischargeMedical misconduct
References
17
Case No. 03-98-00340-CV
Regular Panel Decision
Jun 17, 1999

Texas Natural Resource Conservation Commission Texas Farm, Inc. And Dean Paul D/B/A Paul Farms/Accord Agriculture, Inc. v. Accord Agriculture, Inc./Texas Natural Resource Conservation Commission Texas Farm, Inc. And Dean Paul D/B/A Paul Farms

Accord Agriculture, Inc. (Accord) initiated a lawsuit against the Texas Natural Resource Conservation Commission (TNRCC), challenging the validity of rules established for concentrated animal feeding operations (CAFOs). Accord contended that the TNRCC failed to meet the Administrative Procedure Act's (APA) reasoned justification requirement and exceeded its statutory authority in promulgating these rules. The trial court invalidated the CAFO rules due to the lack of reasoned justification but dismissed Accord's claims regarding a 'takings' violation and the constitutionality of the Right to Farm Act. On appeal, the Court of Appeals affirmed the invalidation of the CAFO rules and the dismissal of the 'takings' claim. However, it reversed the dismissal of Accord's challenge to the Right to Farm Act, remanding that specific issue for further proceedings.

Administrative Procedure ActReasoned JustificationConcentrated Animal Feeding OperationsEnvironmental RegulationWater QualityAir QualityDeclaratory JudgmentStandingTakings ClaimRight to Farm Act
References
55
Case No. MISSING
Regular Panel Decision

DeLeon v. Gurda Farms, Inc. (In Re Gurda Farms, Inc.)

This case involves an appeal by thirteen migrant seasonal farmworkers (plaintiffs-appellants), who are creditors of defendants-bankrupts Gurda Farms, Inc. and Stanley Gurda. The farmworkers challenged a Bankruptcy Court order that denied their request to proceed in forma pauperis (without payment of fees) in their appeal. The plaintiffs had previously obtained a judgment against the defendants under the Farm Labor Contractor Registration Act of 1963 and were prosecuting that action in forma pauperis when the defendants filed for bankruptcy, automatically staying the civil suit. The core legal question is whether 28 U.S.C. § 1915(a), which allows individuals to proceed in forma pauperis, is applicable to creditors appealing a bankruptcy court's decision, especially given the Supreme Court's ruling in United States v. Kras. The District Court distinguished this case from Kras, noting the plaintiffs' pre-existing in forma pauperis status and the minimal impact on the bankruptcy system's self-supporting goal. The court granted the plaintiffs leave to prosecute this appeal in forma pauperis.

In Forma PauperisBankruptcy AppealCreditor RightsFarm Labor Contractor Registration ActStatutory InterpretationConstitutional LawDue ProcessEqual ProtectionReferees' Salary ActBankruptcy Fees
References
13
Case No. CA 13-01811
Regular Panel Decision
Jul 03, 2014

BISH, ROBERT v. ODELL FARMS PARTNERSHIP

Plaintiff Robert Bish, a cement truck driver, sustained injuries while cleaning his employer's truck on property owned by defendant Odell Farms Partnership. Bish filed a Labor Law action, alleging violations of Labor Law § 240 (1) and § 241 (6). The Supreme Court partially denied defendant's motion for summary judgment. On appeal, the Appellate Division, Fourth Judicial Department, reversed the lower court's order, granted the defendant's motion in its entirety, and dismissed the complaint. The court held that routine cleaning of a cement truck was not an activity protected under Labor Law § 240 (1) as it did not constitute "erection, demolition, repairing, altering, painting, cleaning or pointing of a building or structure," nor was it "construction work" under Labor Law § 241 (6). A dissenting opinion argued that issues of fact existed regarding whether plaintiff was engaged in protected construction activity.

Labor LawConstruction SafetyWorker InjurySummary Judgment MotionAppellate ReviewCement Truck CleaningStatutory InterpretationActivity CoverageRoutine Maintenance ExclusionPersonal Injury Lawsuit
References
14
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