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

CourtDistrict Court, W.D. Washington
DecidedFebruary 4, 2025
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. 2025).

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, ORDER 9 Plaintiff, 10 v. 11 UNITED STATES DEPARTMENT OF 12 LABOR; JULIE A SU, in her official capacity, Acting United States Secretary of 13 Labor,

14 Defendants. 15

16 I 17 INTRODUCTION 18 This matter comes before the Court on Plaintiff Familias Unidas por la Justicia, AFL- 19 CIO’s Motion to Complete and Supplement the Administrative Record, Dkt. # 85, Federal 20 Defendants’ Cross-Motion to Supplement the Administrative Record and for Partial Summary 21 Judgment, Dkt. # 89, and Familias’s Motion for Leave to File Second Amended Complaint, Dkt. 22 # 111. The Court has reviewed the materials filed in support of and in opposition to the motions, 23 the record, and the governing law. 24 1 Being fully advised, the Court GRANTS Federal Defendants’ cross-motion for partial 2 summary judgment. The Court DENIES both Familias’s motion to complete the record and 3 Federal Defendants’ cross-motion to supplement the record as moot. The Court GRANTS in

4 part Familias’s motion to supplement the record as to the Besso and Baldwin Declarations. The 5 Court DENIES in part Familias’s motion to supplement the record as to all other proposed 6 documents. The Court DENIES Familias’s motion for leave to file a second amended complaint 7 as moot. 8 II BACKGROUND 9 Under the H-2A program, employers may bring temporary foreign workers into the 10 United States. 8 U.S.C. § 1188. Before an employer can obtain a visa for a foreign worker, the 11 employer must apply for a certification from the United States Department of Labor (DOL) that 12 there are not enough workers at the time and place to fulfill the employer’s need, and that 13 employment of a foreign worker “will not adversely affect the wages and working conditions of 14 workers in the United States similarly employed.” Id. (a)(1)(A)–(B). DOL regulations require 15 H-2A employers in agriculture to pay a wage that is either the Adverse Effect Wage Rate 16 (AEWR) (a state-specific hourly minimum wage) or a prevailing wage rate.1 17 Because prevailing wages can include piece-rate wages (i.e., pay based on the amount of 18 a crop harvested instead of the number of hours worked) and hourly rates of pay higher than the 19 AEWR, DOL recognizes that prevailing wages “serve as an important protection for workers.” 20 88 Fed. Reg. 12760, 12775 (Feb. 28, 2023). Although DOL determines the AEWR, 20 C.F.R. 21

22 1 Under 20 C.F.R. § 655.120(a), H-2A employers are required to pay the wage that is at least the highest of: (1) the AEWR; (2) a prevailing wage rate; (3) the agreed-upon collective bargaining wage; 23 (4) the Federal minimum wage; or (5) the State minimum wage. But in agriculture, the AEWR and the prevailing wage are the only relevant wages because federal and state minimum wages are lower and 24 collective bargaining agreements are not common in the industry. Dkt. # 40 at 2–3. 1 § 655.1300, it delegates to state workforce agencies (SWAs) the task of collecting data to 2 calculate prevailing wage rates. See 20 C.F.R. § 655.1300(c). SWAs follow DOL guidelines for 3 this task and then submit the prevailing wage rates and the survey methods used to DOL for

4 validation. See 20 C.F.R. § 655.120(c); 87 Fed. Reg. 61660, 61679, 61689 (Oct. 12, 2022). 5 In 2022, DOL issued regulations that changed the way that prevailing wages are 6 calculated, 87 Fed. Reg. 61660, and a rule that prevailing wages expire after one year, 20 C.F.R. 7 § 655.120(c)(2), (One-Year rule). Relying on these new regulations, Washington’s SWA, the 8 Employment Security Department (ESD), conducted and submitted a survey to DOL for review. 9 Dkt. # 34 at 2. But while DOL was reviewing the submission, the prior prevailing wage rates 10 expired under the One-Year rule. Without a prevailing wage in effect, there was uncertainty as 11 to the wages that workers would be paid. See Dkt. # 40 at 17–20. 12 A. Preliminary Injunction

13 Before DOL published new prevailing wage rates for Washington, Familias sued DOL 14 and Julie Su, in her official capacity as Acting United States Secretary of Labor to “challeng[e] 15 the agency’s 2022 prevailing wage rules related to the federal ‘H-2A’ temporary agricultural visa 16 program as well as certain policies and practices implementing those prevailing wage 17 regulations.” Dkt. # 67 at 1, ¶ 1. Familias filed a Motion for Preliminary Injunction, Dkt. # 9, to 18 (i) enjoin the One-Year rule; (ii) enjoin the 25% rule, 20 C.F.R. § 655.120(c)(1)(ix),2 a rule that 19 Familias alleges contributed to ESD’s 2022 survey finding of almost no prevailing piece-rate 20 21

22 2 The 25% rule requires the Office of Foreign Labor Certification (OFLC) administrator to issue a prevailing wage if, in addition to other requirements, “the estimated universe of employers is at least 4” 23 and “the wages paid by a single employer represent no more than 25 percent of the sampled wages in the unit of pay used to compensate the largest number of U.S. workers whose wages are reported in the 24 survey.” 1 wages, Dkt. # 67 at 11, ¶ 50; and (iii) rescind DOL’s approval of ESD’s population estimate 2 survey method and direct ESD to conduct its survey with a different method. 3 On July 2, 2024, the Court enjoined the One-Year rule and ordered DOL to reinstate the

4 prevailing wage rates based on a 2020 survey, which were published in January 2022. Dkt. # 40 5 at 21–22. The Court denied Familias’s motion as to the 25% rule and DOL’s approval of ESD’s 6 population estimate survey method because Familias did not provide enough information about 7 DOL’s decision-making process. Id. at 16. 8 B. Joinder and Dismissal of ESD 9 The parties disputed whether ESD was a necessary party because Familias challenged 10 ESD’s implementation of DOL’s regulations. Federal Defendants filed a Motion to Dismiss for 11 Failure to Join a Party Under Rule 19. Dkt. # 50. The Court ordered ESD to be made a party to 12 this suit because it was unclear whether ESD would invoke state sovereign immunity. Dkt. # 63

13 at 5–6. Familias amended its complaint to join ESD and its Commissioner in her official 14 capacity (State Defendants). Dkt. # 67. 15 Once joined, State Defendants filed a Motion to Dismiss on state sovereign immunity 16 grounds. Dkt. # 79. Familias consented to dismissal of ESD and the Court concluded that 17 Familias did not sufficiently allege that ESD’s Commissioner was violating federal law. Dkt. 18 # 117 at 2–3. 19 Thus, the Court dismissed State Defendants from this case. Id. at 8. But while State 20 Defendants were still joined, the parties filed additional motions. 21 C. Familias’s Motion for Discovery and Final Agency Action Issue 22 After amending its complaint to join State Defendants but before the Court dismissed

23 them from this case, Familias filed a Motion for Discovery. Dkt. # 69. Based on its allegations 24 that ESD’s survey method is flawed, Familias sought “discovery of the disaggregated complete 1 survey response data that ESD used to do its calculations . . . along with information about the 2 essential components of the methodology.” Id. at 1–2.

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