Familias Unidas Por La Justicia AFL-CIO v. United States Department of Labor

CourtDistrict Court, W.D. Washington
DecidedJuly 2, 2024
Docket2:24-cv-00637
StatusUnknown

This text of Familias Unidas Por La Justicia AFL-CIO v. United States Department of Labor (Familias Unidas Por La Justicia AFL-CIO v. United States Department of Labor) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Familias Unidas Por La Justicia AFL-CIO v. United States Department of Labor, (W.D. Wash. 2024).

Opinion

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4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 FAMILIAS UNIDAS POR LA JUSTICIA, CASE NO. 2:24-cv-00637-JHC 8 AFL-CIO, Plaintiff, ORDER 9 v. 10 UNITED STATES DEPARTMENT OF 11 LABOR; JULIE A SU, in her official capacity, Acting United States Secretary of 12 Labor, Defendants. 13

14 I 15 INTRODUCTION 16 This matter comes before the Court on Plaintiff’s Motion for Preliminary Injunction. 17 Dkt. # 9. Plaintiff, Familias Unidas por la Justicia, AFL-CIO, (FUJ) is a labor union that 18 represents farmworkers throughout Washington State. Plaintiff challenges “the lawfulness of 19 [the United States Department of Labor’s (DOL)] new prevailing wage rules and DOL’s 20 application of these rules to Washington.” Dkt. # 9 at 2. Plaintiff asks the Court to enjoin the 21 DOL from enforcing 20 C.F.R. § 655.120(c)(2) (the One-Year rule); and 20 C.F.R. § 22 655.120(c)(1)(ix) (the 25% rule). Plaintiff requests that the Court reinstate the prevailing wages 23 from the 2020 survey. Plaintiff also asks the Court to rescind DOL’s approval of the 24 1 Washington State Employment Security Department’s (ESD) population estimate methodology 2 and direct ESD to conduct its prevailing wage survey using different methodology. 3 For the reasons discussed below, the Court GRANTS in part, and DENIES in part

4 without prejudice, Plaintiff’s motion. The Court ENJOINS enforcement of the One-Year rule in 5 Washington, and ORDERS DOL to reinstate the 2020-Survey prevailing wage rates, published 6 in January 2022, in Washington. The Court DENIES without prejudice Plaintiff’s motion as to 7 the 25% rule and its claims regarding ESD’s population estimate methodology. 8 II BACKGROUND 9 Below is a summary of this case’s background. 10 11 A. Regulatory structure 12 Under the H-2A program, employers may bring temporary foreign workers into the 13 United States. 8 U.S.C. § 1188. Before an employer can obtain a visa for a foreign worker, the 14 employer must apply for a certification from DOL that there are not enough workers at the time 15 and place to fulfill the employer’s need, and that employment of a foreign worker “will not 16 adversely affect the wages and working conditions of workers in the United States similarly 17 employed.” Id. (a)(1)(A)–(B). Accordingly, DOL regulations require H-2A employers to: 18 19 [P]ay a wage that is at least the highest of: 20 (1) The [Adverse Effect Wage Rate] [(]AEWR[)]; 21 (2) A prevailing wage rate, if the OFLC Administrator has approved a prevailing wage survey for the applicable crop activity or agricultural activity and, if 22 applicable, a distinct work task or tasks performed in that activity, meeting the requirements of paragraph (c) of this section; 23 (3) The agreed-upon collective bargaining wage; 24 1 (4) The Federal minimum wage; or (5) The State minimum wage. 2 20 C.F.R. § 655.120(a). In agriculture, the AEWR and the prevailing wage are the only relevant 3 wages, as federal and state minimum wages are lower and collective bargaining agreements are 4 not common in the industry. Dkt. # 18-1 at 3. The AEWR is a state-specific hourly minimum 5 wage set by DOL. 20 C.F.R. § 655.1300. In Washington, the AEWR for 2024 is $19.25 per 6 hour. H-2A Adverse Effect Wage Rates, U.S. Department of Labor, https://flag.dol.gov/wage- 7 data/adverse-effect-wage-rates. 8 9 In agriculture, a prevailing wage may include piece-rate wages. Under such a 10 compensation structure, employers pay workers by the amount of a crop—typically fruit— 11 harvested instead of the number of hours worked. See Dkt. # 21. Plaintiff submitted 12 declarations of domestic farmworkers who state that they are generally paid piece-rate wages, 13 earn substantially more money under that compensation structure, and rely on such wages to 14 support themselves and their families. See Dkt. # 11, 12, 13, 14, 15, 16. The Ninth Circuit has 15 recognized that piece-rate wages are “at least the highest of the listed wages because a piece-rate 16 wage offers workers the opportunity to earn more than they might under an hourly wage.” 17 Torres-Hernandez v. DOL, No. 23-35582, 2024 WL 2559562, at *1 (9th Cir. May 24, 2024). 18 DOL also recognizes that prevailing wages “serve as an important protection for workers in crop 19 and agricultural activities that offer piece rate pay or higher hourly rates of pay than the AEWR.” 20 88 Fed. Reg. 12760, 12775 (Feb. 28, 2023) (emphasis added). 21 DOL delegates to state workforce agencies (SWAs) the task of collecting data to 22 calculate prevailing wage rates. See 20 CFR § 655.1300(c). SWAs follow DOL guidelines for 23 this task and then submit the prevailing wage rates, along with the survey methodologies used, to 24 1 DOL for validation. See 20 C.F.R. § 655.120(c) (laying out criteria SWAs must follow to 2 calculate prevailing wages that meet DOL standards); see also 87 Fed. Reg. 61660, 61679, 3 61689 (Oct. 12, 2022) (describing the way SWAs should conduct prevailing wage surveys under

4 the new regulations and how DOL validates the survey results and publishes the prevailing wage 5 findings). The SWA in Washington is ESD. State Workforce Agencies, U.S. Department of 6 Labor, https://www.dol.gov/agencies/eta/wotc/contact/state-workforce-agencies. 7 In 2022, DOL promulgated regulations that changed the way prevailing wages are 8 calculated. 87 Fed. Reg. 61660. Based on these new regulations, ESD conducted and submitted 9 its 2023 survey to DOL for review. Dkt. # 34 at 2. DOL is still reviewing the submission and 10 has not published any prevailing wage rates for Washington State for the 2024 harvest season. 11 Id. Further, based on its new One-Year rule, all prevailing wage rates older than one year have 12 expired. 20 C.F.R. § 655.120(c)(2). Thus, there are currently no prevailing wages required for 13 H-2A workers in Washington. 14 B. Prior Case 15 16 In 2020, FUJ (along with another plaintiff) sued DOL in the Eastern District of 17 Washington challenging (1) changes that DOL made in 2019 to the method it used to calculate 18 piece-rate prevailing wages and (2) various other DOL policies and practices around calculating 19 the prevailing wage rate. Torres-Hernandez v. DOL, No. 1:20-CV-3241-SMJ, Dkt. # 1 at 35–36 20 (E.D. Wash. Dec. 17, 2020). In the Second Amended Complaint (SAC) there, the plaintiffs said 21 that DOL violated the Administrative Procedure Act (APA), 5 U.S.C. § 706(2)(A), (D), 22 procedurally by changing its methodology for calculating the prevailing wage rate in 2019 23 without notice and opportunity to comment. The plaintiffs argued that DOL substantively 24 1 violated the APA by (1) changing “the hourly wage guarantee policy and practice” to consider 2 “hourly wage guarantees” associated with piece rate wages in the prevailing wage calculation 3 instead of looking at the actual piece rates; (2) failing “to use worker surveys to verify employer

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Familias Unidas Por La Justicia AFL-CIO v. United States Department of Labor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/familias-unidas-por-la-justicia-afl-cio-v-united-states-department-of-wawd-2024.