## Facts

- Rafael Ruiz worked for Farmer Brothers Coffee in warehouse/shipping operations.
- Ruiz was not authorized to work in the United States at the time of hire and injury.
- To obtain employment, Ruiz presented work-authorization documents and used a Social Security number that were not lawfully his.
- Ruiz suffered an industrial injury and sought workers’ compensation benefits.
- A workers’ compensation judge found Ruiz qualified as an “employee” under Labor Code § 3351(a) and could pursue benefits.
- Farmer Brothers petitioned for reconsideration, arguing federal preemption under the Immigration Reform and Control Act of 1986 (IRCA) and that Ruiz’s alleged misrepresentations barred benefits under Insurance Code § 1871.4.
- The Workers’ Compensation Appeals Board denied reconsideration, and Farmer Brothers sought writ review.

## Issues

1. Whether IRCA preempts California statutes treating an undocumented worker as an “employee” eligible for workers’ compensation benefits.
2. Whether alleged fraud in obtaining employment and presenting a claim bars workers’ compensation benefits under Insurance Code § 1871.4 absent a criminal conviction.

## Decision

- The Court of Appeal affirmed the WCAB’s decision.
- IRCA did not preempt California’s workers’ compensation coverage for undocumented workers.
- Ruiz remained an “employee” within the workers’ compensation scheme even if he obtained employment using false immigration-related documents.
- Insurance Code § 1871.4 did not bar benefits because the statutory ineligibility applies only upon conviction, and Ruiz had not been convicted.

## Legal Principles

- Under Labor Code § 3351(a), “employee” includes persons “whether lawfully or unlawfully employed,” including aliens.
- IRCA does not occupy the field of workers’ compensation and does not create a conflict that prevents California from providing no-fault compensation for on-the-job injuries sustained during actual employment.
- Labor Code § 1171.5 makes immigration status generally irrelevant to state labor-law liability and remedies, subject to limitations where a requested remedy would require violation of federal immigration law.
- Insurance Code § 1871.4’s disqualification from receiving workers’ compensation benefits is triggered by a criminal conviction under that statute; allegations or administrative findings of misrepresentation, without conviction, do not automatically extinguish entitlement to benefits.

## Conclusion

The court held that California may treat undocumented workers as employees for workers’ compensation purposes without conflicting with IRCA, and that Insurance Code § 1871.4 does not bar benefits based on alleged fraud unless the worker has been convicted under that statute.


Farmer Bros. Coffee v. Workers’ Comp. Appeals Bd., 133 Cal. App. 4th 533, 35 Cal. Rptr. 3d 23 (Ct. App. 2005)