Adams Fruit Co., Inc. v. Barrett - 494 U.S. 638 (1990)
U.S. Supreme Court
Adams Fruit Co., Inc. v. Barrett, 494 U.S. 638 (1990)
Adams Fruit Co., Inc. v. Barrett
Argued January 17, 1990
Decided March 21, 1990
494 U.S. 638
Respondents, migrant farmworkers employed by petitioner, received benefits under Florida workers' compensation law for injuries they suffered in an automobile accident while traveling to work in petitioner's van. They subsequently filed suit against petitioner in Federal District Court, alleging that their injuries were attributable in part to petitioner's intentional violations of the motor vehicle safety provisions of the Migrant and Seasonal Agricultural Worker Protection Act (AWPA), 29 U.S.C. § 1801 et seq., and accompanying regulations. They sought actual and statutory damages for such violations pursuant to AWPA's private right of action provision, § 1854. The court granted petitioner summary judgment on the ground that the state workers' compensation law provides that its remedy is exclusive, and that respondents' receipt of benefits under that law therefore precluded them from recovering damages under AWPA for the same injuries. The Court of Appeals reversed, holding that such an exclusivity provision does not bar a private AWPA suit.
Held: Exclusivity provisions in state workers' compensation laws do not bar migrant workers from availing themselves of a private right of action under § 1854. Pp. 494 U. S. 642-651.
(a) The explicit language of AWPA's enforcement provisions -- which establishes a private right of action for "[a]ny person aggrieved by a violation," § 1854(a) -- indicates that that right is unaffected by the availability of remedies under state workers' compensation law. A congressional intent to the contrary is not established by AWPA's motor vehicle safety provisions, which permit employers to satisfy the statute's insurance and liability bond requirements through their state workers' compensation insurance. The safety provisions appear in a Title far removed from the enforcement provisions, and the latter provisions contain Congress' sole express limitation on the availability of relief, which applies where no attempt was made to resolve the disputed issues before litigation. Had Congress intended to limit further the availability of AWPA relief based on the adequacy of state workers' compensation remedies, it would have made that purpose clear in AWPA's enforcement provisions. Moreover, the insurance waiver provision is not inconsistent with the availability of overlapping remedies under workers' compensation
laws and AWPA, since the agricultural employer, whether or not it has enrolled in a workers' compensation plan, will be liable under AWPA's enforcement provisions if the employee's actual damages exceed the required minimum insurance coverage. Although Congress may choose to establish state remedies as adequate alternatives to federal relief, it cannot be assumed that private federal rights of action are conditioned on the unavailability of state remedies absent some indication to that effect. Cases in which this Court has harmonized federal statutes that provide overlapping federal remedies are not to the contrary. Pp. 494 U. S. 643-647.
(b) AWPA preempts state law to the limited extent that it does not permit States to supplant, rather than to supplement, the statute's remedial scheme. Section 1871 -- which provides that AWPA
"is intended to supplement State law, and compliance with [the statute] shall not excuse any person from compliance with appropriate State law and regulation"
-- does not require this Court to give effect to the Florida exclusivity provision, even if that provision were intended to withdraw AWPA's private right of action. Although § 1871 permits States to supplement the statute's remedial scheme, it cannot be viewed as authorizing them to replace or supersede AWPA remedies. Petitioner's claim that Congress intended to preserve the particular balance state workers' compensation laws generally strike between assurance of compensation and limited and exclusive employer liability is off target, since the fact that AWPA may affect that balance does not suggest that Congress intended AWPA's remedial provisions to be effective only in certain States. Federal law applies in all States, and the scope of federal law is not curtailed where it conflicts with the policies purportedly underlying some state regulatory schemes. State exclusivity provisions that attempt to withdraw federal remedies directly conflict with the federal scheme's purposes, and cannot be viewed as permissible interstitial regulation. Pp. 494 U. S. 647-649.
(c) Even if AWPA's language establishing a private right of action is ambiguous as to the statute's preemptive scope, this Court need not defer to the Department of Labor's position that state workers' compensation benefits, where applicable, are the exclusive remedy for loss under the statute. Congress expressly established the Judiciary, and not the Department, as the adjudicator of AWPA private rights of action, and the Department's statutory authorization to promulgate motor vehicle safety standards cannot bootstrap that agency into an area in which it has no jurisdiction. Pp. 494 U. S. 649-650.
867 F.2d 1305, affirmed.
MARSHALL, J., delivered the opinion for a unanimous Court.