Rodriguez v. Brand West DairyAnnotate this Case
These consolidated appeals presented an issue to the New Mexico Supreme Court on whether farm and ranch laborers' exclusion from coverage under the state Workers' Compensation Act violated the rights of those workers under the Equal Protection Clause of Article II, Section 18 of the New Mexico Constitution in light of the fact that other agricultural workers are not singled out for exclusion. After review of these cases, the Supreme Court concluded that there was nothing to distinguish farm and ranch laborers from other agricultural employees and that purported government interests such as cost savings, administrative convenience, and other justifications related to unique features of agribusiness bore no rational relationship to the Act’s distinction between these groups. "This is nothing more than arbitrary discrimination and, as such, it is forbidden by our Constitution." Accordingly, the Court held that the farm and ranch laborer exclusion contained in Section 52-1-6(A) of the Act was unconstitutional, and these cases were remanded for further proceedings.