## Facts

- Case Farms operated a poultry-processing plant in Winesburg, Ohio, and sought workers by using a Texas labor contractor, America’s Tempcorps (ATC), and an ATC recruiter.
- In 1996, ATC recruited low-income workers in Texas for jobs at Case Farms, providing bus tickets and a small food allowance and representing that employment, housing, and transportation would be provided.
- Workers arrived in Ohio to housing found to be overcrowded, unfurnished, and vermin-infested; some workers slept on the floor, and occupancy levels were extreme.
- Transportation to the plant was allegedly unsafe and overcrowded, including vehicles with improvised seating.
- Plaintiffs alleged failures to provide accurate written disclosures of employment terms, failures to meet statutory housing and transportation standards, misleading recruitment representations, and wage violations.
- Plaintiffs sued under the Migrant and Seasonal Agricultural Worker Protection Act (AWPA), the Fair Labor Standards Act (FLSA), and state-law theories (including breach of contract, fraud, and negligent misrepresentation).
- After a bench trial, the court issued findings of fact and conclusions of law under Federal Rule of Civil Procedure 52(a).

## Issues

1. Whether ATC and its recruiter acted as Case Farms’ agents with actual authority (express or implied), making Case Farms responsible for their recruitment-related conduct.
2. Whether Case Farms and ATC were joint employers under AWPA, permitting AWPA liability based on the realities of control and supervision.
3. Whether Case Farms violated AWPA and FLSA through deficient disclosures, use of an unregistered contractor, substandard housing and transportation, misleading representations, and wage violations.
4. Whether plaintiffs proved state-law claims arising from the recruitment and employment arrangements.

## Decision

- The court found an actual principal–agent relationship between Case Farms and ATC and concluded Case Farms was responsible for acts taken within the scope of that agency.
- The court also found Case Farms and ATC were joint employers under AWPA (at least as to the workers recruited through ATC), based on Case Farms’ control over core employment conditions.
- The court rejected Case Farms’ argument that it fell outside AWPA coverage due to the nature of its operations, interpreting AWPA broadly to protect migrant workers in recruitment, housing, and transportation.
- The court held Case Farms liable for multiple AWPA and FLSA violations tied to recruitment practices, inadequate disclosures, substandard housing and transportation, and wage-related failures.
- The court awarded statutory damages for AWPA violations and held Case Farms accountable for ATC’s and the recruiter’s conduct undertaken in the recruitment and employment relationship.

## Legal Principles

- A principal may be liable for an agent’s acts when an actual agency relationship exists through express or implied delegation of authority and the acts are within the scope of employment.
- Express authority to recruit and hire may carry implied authority to carry out acts proper, usual, and necessary to accomplish recruitment, including arrangements related to travel, housing, and transportation.
- Under AWPA, an entity may be liable as a joint employer when it exercises substantial control over the work relationship, including supervision, pay-related decisions, and scheduling, notwithstanding the presence of a labor contractor.
- AWPA is construed as a remedial worker-protection statute; courts apply it in light of the practical realities of recruitment and employment rather than formal labels designed to shift responsibility.
- Employers that obtain workers through labor contractors may remain liable for statutory violations connected to disclosures, recruitment representations, housing, transportation, and wage compliance.

## Conclusion

The court held that Case Farms could not avoid AWPA and FLSA responsibility by interposing a labor contractor, finding both actual agency and joint-employer status and awarding statutory damages for violations tied to misleading recruitment, deficient disclosures, substandard housing and transportation, and wage-related failures.


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