The U.S. Supreme Court heard arguments on November 10 over who can decide whether a farm owes back wages and civil penalties under the H-2A seasonal worker program. In Department of Labor v. Sun Valley Orchards, the question is whether the department can decide those claims in its own proceedings or must take them to federal court.
The dispute starts with a document called a job order. In 2015, the New Jersey farm used one to promise free cooking facilities and transportation to a grocery store. According to the Third Circuit’s account, the Labor Department concluded that workers lacked meaningful kitchen access and were charged for meals without notice. In that same enforcement case, an administrative law judge reduced the department’s initial assessments to $344,945.80 in back wages and $211,800 in civil penalties. The department’s Administrative Review Board upheld those amounts.
The job order does two things. It sets out what workers are promised, and it records conditions the employer accepts to hire through H-2A. In the argument transcript, the government’s lawyer stressed the second role: the department was enforcing commitments the employer made to the government in exchange for access to the program. The farm’s lawyer stressed the first: deciding whether a farm breached those promises and owes money resembles a contract case that belongs in federal court.
In 2025 the Third Circuit sided with the farm. It held that Article III of the Constitution required the department to proceed in federal district court in this case and sent the case back with instructions to enter judgment for Sun Valley. It did not reach the farm’s separate argument that the department lacked statutory authority to impose the remedies through administrative proceedings.
The Supreme Court docket records the hearing and lists no decision. The question to watch is where liability gets decided. A federal court reviewing a completed agency proceeding plays a different role from a court hearing the enforcement case in the first instance, a distinction the farm’s lawyer discussed in oral argument. The hearing itself did not change the terms employers must offer workers.