EEOC v. Global Horizons, Inc., No. 16-35528 (9th Cir. 2019)
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The common-law agency test is the most appropriate test for determining whether an entity is a joint employer under Title VII of the Civil Rights Act of 1964. The EEOC brought an enforcement action under Title VII on behalf of Thai workers alleging discrimination charges against Green Acre Farms and Valley Fruit Orchards. The Ninth Circuit reversed the district court's dismissal of the EEOC's allegations regarding non-orchard-related matters, which in turn affected each of the other decisions under review.
The panel held, under the common-law agency test, that the EEOC plausibly alleged that defendants were also joint employers with respect to non-orchard-related matters; the EEOC's allegations stated a plausible basis for holding Green Acre liable for discrimination relating to non-orchard-related matters; and the district court should have granted the EEOC leave to amend its complaint regarding Valley Fruit's liability with respect to such matters.
Court Description: Equal Employment Opportunity Commission. The panel reversed the district court’s orders in an enforcement action brought by the Equal Employment Opportunity Commission (“EEOC”) under Title VII of the Civil Rights Act of 1964 on behalf of Thai workers alleging discrimination charges against Green Acre Farms and Valley Fruit Orchards (the “Growers”). The Growers retained Global Horizons, Inc., a labor contractor, to obtain temporary workers for their orchards. Global Horizons recruited workers from Thailand and brought them to the United States under the H-2A guest worker program. The district court entered a default judgment against Global Horizons after it discontinued its defense in the action; this case focuses solely on the liability of the Growers. The district court granted in part the Growers’ Fed. R. Civ. P. 12(b)(6) motions to dismiss. The district court drew a distinction between orchard-related matters (managing, supervising, and disciplining the Thai workers at the orchards) and non-orchard-related matters (housing, feeding, transporting, and paying the workers). The panel held that the district court erred in holding that the Growers could not be held liable under Title VII for non- orchard-related matters.
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