THE RECORDER

March 4, 2010

 

Calif. Farm Worker Case May Clarify Definition of 'Employer'

 

By Mike McKee

Farm workers filled the California Supreme Court on Tuesday to hear arguments in a case about unpaid wages that could affect millions of low-paid employees in unrelated professions across the business spectrum.

The court is being asked to define what constitutes an employer within the meaning of state Industrial Welfare Commission wage orders. In the case at hand, farm workers contend that two companies that market and sell strawberries fall within that meaning and are liable for the unpaid wages of about 180 berry pickers after the independent contractor who hired them became insolvent.

Two attorneys representing the marketing companies said after oral arguments that the court's ruling will have an impact on any business relationship in which a company hires an independent contractor. One mentioned department stores' contracts with shoemakers, while an amicus curiae brief filed by several legal services groups cited food delivery services for restaurants and janitors working for subcontractors of large management companies.

As Justice Marvin Baxter noted during oral arguments: "This isn't an arrangement peculiar to agriculture."

After not getting paid for harvesting berries in 2000, farm workers sued grower Isidro Munoz and two sales and marketing companies, Guadalupe-based Apio Inc. and Combs Distribution Co. of Santa Maria, alleging that all three were employers as defined by the IWC's wage orders as anyone who exercises "control over wages, hours or working conditions."

Apio and Combs loaned Munoz money under a complex contract that gave them the right to sell the fruit he grew and oversee his operations. After Munoz filed for bankruptcy, the farm workers focused their attention on the two companies, saying that the IWC also defined employers as anyone who "suffers or permits any person to work."

The appellate court disagreed, holding in 2003 that Apio and Combs "did not exercise sufficient control over the workers and the agricultural operation" to be employers.

During oral arguments Tuesday, Justice Joyce Kennard addressed that topic, saying that while state labor codes allowing employees to bring suits for unpaid wages don't define an employer, "one could, in my view, come to the reasonable conclusion that it was Munoz who was the employer."

She then suggested that Apio and Combs could be considered more like brokers, rather than employers.

The farm workers' lawyer, William Hoerger, director of litigation advocacy and training for San Francisco-based California Rural Legal Assistance, disagreed.

"It is clear that Apio controlled every single aspect of the operation from beginning to end," he said, noting that it leased the land to Munoz and decided such things as when to harvest, how much to harvest and whether to harvest at all.

Combs' involvement wasn't as extensive, Hoerger said, but its owners "called the financial shots" in the arrangement with Munoz.

Both businesses, he added, made payments in advance to Munoz to have exclusive rights to the crop.

Baxter, who grew up on a farm near Fresno, took great interest in the case, asking several questions of all three attorneys involved in the arguments.

Baxter, who loves hypotheticals, had one for Salinas lawyer Effie Anastassiou, who represented Apio. What if, he asked, a farmer hires an independent contractor to prune vines, pays him the full amount owed and the contractor absconds with all the money, leaving the farm workers holding the bag?

Would that, he asked, create employer responsibility for the farmer?

Anastassiou said it would depend upon whether the contractor was truly independent or the farmer actually controlled the work.

Terrence O'Connor, a partner with Salinas' Noland Hamerly Etienne & Hoss who represented Combs Distribution, argued that his client and the farm workers were both victims.

"The real bad guy, if there is one in this case," he said, "is Munoz."

A ruling in Martinez v. Combs, S121552, is due within 90 days.