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

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. MISSING
Regular Panel Decision

Mid-Hudson Legal Services, Inc. v. G & U, INC.

Plaintiffs, a federally-funded legal aid organization and its attorneys, sought an injunction against a corporate farm and its proprietors for denying them access to migrant farmworkers residing on the farm's property. The plaintiffs intended to distribute a Spanish language booklet on farmworker rights and offer legal assistance. Defendants justified their denial based on their right to prevent trespass and accused plaintiffs of fomenting labor unrest and impermissibly soliciting clients. The court found the defendants' arguments unpersuasive, ruling that the farm, operating as a 'company town,' could not deny plaintiffs their First Amendment right to enter and discuss living or working conditions with its inhabitants. Consequently, the court issued a permanent injunction, preventing the defendants from interfering with the plaintiffs' access to the agricultural labor camps for providing services mandated by 42 U.S.C. § 2861 et seq.

Migrant FarmworkersFarmworker RightsFirst AmendmentAccess RightsCompany Town DoctrinePermanent Injunction42 U.S.C. § 1983Legal AidAgricultural Labor CampsCivil Rights
References
8
Case No. 78 Civ. 6252 (CHT)
Regular Panel Decision

Soler v. G & U, Inc.

Approximately 100 migrant farmworkers, as plaintiffs, sued farm owners including G & U, Inc. under the Fair Labor Standards Act for alleged unfair wage deductions for housing. The current motion involved plaintiffs seeking an order to lift a stay, conduct discovery on employee lists from 1980-82, and circulate notice to potential plaintiffs for those years. The court denied the request to circulate notice, deeming it inappropriate without approved amended claims, which could constitute "stirring up litigation." However, it granted the discovery request for employee names and addresses, citing the plaintiffs' counsel's "Catch 22" dilemma. The defendants' counterclaim for attorneys' fees was also denied.

Fair Labor Standards Actwage deductionshousingmigrant farmworkersclass actionopt-innotice of pendencydiscoverystatute of limitationsattorneys' fees
References
12
Case No. MISSING
Regular Panel Decision

Town of Lysander v. Hafner

This case concerns the Town of Lysander's zoning ordinance, which mandates a minimum living area of 1,100 square feet for single-story single-family dwellings, applied to mobile homes for migrant workers on a commercial farm. The defendant farm owners challenged this ordinance, arguing it unreasonably restricted farm operations within an agricultural district, contrary to Agriculture and Markets Law § 305-a (1) (a). While lower courts sided with the Town, the Court of Appeals reversed, holding that "on-farm buildings" include farmworker residences under the statute. The Court found the Town failed to demonstrate that its restriction on mobile homes was necessary to protect public health or safety, thus granting summary judgment to the defendants and remitting the case for further proceedings.

zoning ordinanceagricultural districtsfarm operationsmobile homesmigrant worker housingstatutory interpretationpublic health and safetysummary judgmentland use regulationAgriculture and Markets Law
References
3
Case No. MISSING
Regular Panel Decision

Lewis Family Farm, Inc. v. New York State Adirondack Park Agency

Lewis Family Farm (Lewis Farm) sought to build housing for farm workers in Essex County, within the Adirondack Park. The Adirondack Park Agency (APA) asserted jurisdiction, issued a cease and desist order, and levied a $50,000 civil penalty, claiming the structures were 'single family dwellings' requiring a permit. Lewis Farm challenged this, contending the housing constituted 'agricultural use structures' exempt from APA jurisdiction under the Adirondack Park Agency Act and the Wild, Scenic and Recreational Rivers System Act. The Supreme Court annulled the APA's determination, agreeing with Lewis Farm. The Appellate Division affirmed the Supreme Court's judgment, concluding that farmworker housing directly and customarily associated with agricultural use falls under the 'agricultural use structure' exemption, thus not requiring an APA permit.

Land UseAdirondack Park Agency ActAgricultural Use StructuresSingle Family DwellingsPermit RequirementsStatutory InterpretationCPLR Article 78Farmworker HousingZoning ExemptionEnvironmental Law
References
15
Case No. 79-895
Regular Panel Decision
Jul 16, 1981

Strait v. Mehlenbacher

The plaintiffs, Farmworker Legal Services of New York, Inc. (FLSNY) and its staff attorneys, filed a motion for partial summary judgment to dismiss the defendants' (Mehlenbacher) third counterclaim. The counterclaim, brought under 42 U.S.C. § 1983, alleged that FLSNY violated the civil rights of migrant workers by interfering with their contractual relationships, privacy, and attempting to "stir up litigation" at the Mehlenbacher Labor Camp, and by refusing to leave the premises. Plaintiffs argued they were a federal agency and federal employees, thus acting under federal, not state, authority, which is a prerequisite for a § 1983 claim. The court found defendants' allegations of conspiracy with state agents insufficient and their interrogatories overly broad, failing to establish that plaintiffs acted "under color of state law." Therefore, the court granted the plaintiffs' motion for partial summary judgment and dismissed the defendants' counterclaim.

Civil Rights ActionSummary Judgment MotionCounterclaim DismissalFederal Question JurisdictionState Action Requirement42 U.S.C. Section 1983Legal Services CorporationMigrant Workers' RightsConspiracy AllegationsDiscovery Abuse
References
16
Case No. MISSING
Regular Panel Decision

Rios v. Marshall

This action was commenced by thirty-eight migrant farmworkers, individually and on behalf of a class, alleging a conspiracy among New York apple growers, Florida sugar cane growers' associations, and various government officials. Plaintiffs claim violations of antitrust and civil rights laws due to the alleged replacement of domestic workers with temporary foreign workers from Jamaica. The defendants moved to dismiss claims on grounds including antitrust immunity, lack of state action, absence of racial animus, statute of limitations, res judicata, lack of personal jurisdiction, and foreign sovereign immunity. The court granted some dismissal motions, particularly those concerning wage-based antitrust claims, civil rights claims under §§ 1981 and 1983, and claims against sovereign entities or for lack of jurisdiction. However, the court denied motions to dismiss certain antitrust claims regarding working conditions and civil rights claims under § 1985. The case will proceed on the surviving claims, with plaintiffs instructed to file an amended complaint.

Migrant WorkersFarmworkersAntitrust LawCivil RightsSherman ActClayton ActConspiracyTemporary Foreign WorkersImmigration LawWagner-Peyser Act
References
73
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