## Facts

- Glassboro Service Association, Inc., a farm labor service, recruited Natividad Vasquez from Puerto Rico under an arrangement that included work and employer-provided living quarters in a New Jersey labor camp.
- The camp provided barracks-style beds and communal facilities; workers paid for meals but not separate rent for the beds.
- After a foreman deemed Vasquez’s work unsatisfactory, Glassboro discharged him.
- Immediately upon termination, Glassboro ordered Vasquez to leave the camp and did not allow him to remain overnight, despite available space.
- Vasquez had little money and no independent housing or immediate means to return to Puerto Rico.
- A nonprofit farmworker legal organization sued seeking reinstatement to the quarters and an injunction barring dispossession except through judicial process.
- Vasquez later found other housing, but the courts treated the dispute as recurring and suitable for decision.

## Issues

1. Whether a farm labor service that provides living quarters to migrant workers may dispossess a discharged worker by self-help or must proceed through judicial process.
2. Whether the worker’s occupancy in employer-provided barracks makes the worker a “tenant” covered by N.J.S.A. 2A:18-61.1(m).
3. Whether a contract allowing immediate removal from employer-provided housing upon discharge violates New Jersey public policy, and whether a term requiring a reasonable time to secure shelter should be implied.

## Decision

- The Supreme Court of New Jersey affirmed the requirement that Glassboro could not use self-help to remove the worker and must seek dispossession through a judicial action.
- The Court held the worker was not a statutory “tenant” within N.J.S.A. 2A:18-61.1(m), yet judicial process was still required.
- The Court held that a contract term effectively permitting immediate displacement without a reasonable opportunity to find shelter was against public policy.
- The Court implied into the employment/housing arrangement a provision giving the worker a reasonable time to obtain alternative housing after termination.
- The Court stated that trial courts may craft equitable relief, including additional time to relocate, assistance in finding housing, provision of return passage, or other appropriate remedies.

## Legal Principles

- An employer or labor service providing housing incident to employment may not use self-help to dispossess a worker who remains in possession; removal must occur through judicial procedures.
- Statutory tenant protections may be inapplicable to employer-provided migrant labor camp occupancy, but courts may still require judicial process to prevent abrupt displacement.
- Where bargaining power is substantially unequal and contractual “consent” is not meaningfully voluntary, courts may refuse to enforce terms that offend public policy.
- Contracts and employment-related housing arrangements may be judicially supplemented with implied terms to avoid outcomes contrary to state public policy, including a reasonable-time-to-relocate requirement.
- Equitable remedies in housing dispossession disputes may be tailored to the worker’s circumstances and the public interest, rather than limited to immediate removal.

## Conclusion

The court required judicial process before removing a discharged migrant farmworker from employer-provided barracks and, based on public policy and unequal bargaining power, implied a contractual right to a reasonable time to secure alternative shelter, authorizing flexible equitable relief.


Vasquez v. Glassboro Serv. Ass'n, Inc., 83 N.J. 86, 415 A.2d 1156 (N.J. 1980)