From Picking Citrus to Fighting for Proper Wages: Migrant Farm Workers Have Standing to Bring Class Action
In Garcia-Celestino v. Ruiz Harvesting, Inc., 2012 WL 602728, at * 1 (M.D. Fla. Feb. 24, 2012), the Middle District of Florida granted class certification to 38 migrant farm workers with respect to their claims that a central Florida citrus farmer, who employed approximately 286 Mexican migrant workers under a single contract, breached a contract with the workers and failed to pay minimum wage in violation of Florida’s Constitution. Prior to determining whether the elements of Fed. R. Civ. P. 23 were satisfied, the Court was required to accept Plaintiff’s substantive allegations as true when determining whether the migrant workers had Article III standing. Because plaintiffs alleged the citrus farmer employed the migrant workers pursuant to a federal foreign agricultural worker program and because plaintiffs alleged the citrus farmer damaged them by failing to pay the appropriate wage rate, unlawfully deducting travel time, and failing to properly reimburse the workers for their expenses, the Court found the migrant farm workers had standing to bring a class action claim. The Court went on to determine that Plaintiffs satisfied the requirements of Rule 23(a) and Rule 23(b)(3).