Snapp & Son, Inc. v. Puerto Rico ex rel. Barez
Annotate this Case
458 U.S. 592 (1982)
U.S. Supreme Court
Snapp & Son, Inc. v. Puerto Rico ex rel. Barez, 458 U.S. 592 (1982)
Alfred L. Snapp & Son, Inc. v. Puerto Rico ex rel. Barez
Argued April 20, 1982
Decided July 1, 1982
458 U.S. 592
Respondent Commonwealth of Puerto Rico filed suit in Federal District Court against petitioners, individuals and companies engaged in the apple industry in Virginia, alleging that petitioners had violated related provisions of the Wagner-Peyser Act and the Immigration and Nationality Act of 1952, and implementing regulations. The purposes of this statutory and regulatory scheme are to give United States workers, including citizens of Puerto Rico, a preference over temporary foreign workers for jobs that become available within this country, to ensure that working conditions of domestic employees are not adversely affected when foreign workers are brought in, and to prohibit discrimination against United States workers in favor of foreign workers. It was alleged that, pursuant to the federal laws, petitioners had reported 787 job openings for temporary farm labor to pick the 1978 apple crop, and that, in violation of such laws, petitioners had discriminated against Puerto Rican workers by failing to provide employment for qualified Puerto Rican migrant farmworkers, by subjecting those Puerto Rican workers that were employed to working conditions more burdensome than those established for temporary foreign workers, and by improperly terminating employment of Puerto Rican workers. Seeking declaratory and injunctive relief in its capacity as parens patriae, Puerto Rico asserted that this alleged discrimination deprived the Commonwealth of its right "to effectively participate in the benefits of the Federal Employment Service System of which it is a part," and thereby caused irreparable injury to the Commonwealth's efforts "to promote opportunities for profitable employment for Puerto Rican laborers and to reduce unemployment in the Commonwealth." The District Court dismissed the complaint, holding that Puerto Rico lacked standing to bring the action in view of the small number of individuals directly involved and the slight impact upon Puerto Rico's general economy that the loss of 787 temporary jobs could have. The Court of Appeals reversed.
Held: Puerto Rico has parens patriae standing to maintain this suit. Pp. 458 U. S. 600-610.
(a) In order to maintain a parens patriae action, a State must articulate an interest apart from the interests of particular private parties, that is, the State must be more than a nominal party. The State must express a "quasi-sovereign" interest, such as its interest in the health and wellbeing -- both physical and economic -- of its residents in general. Although more must be alleged than injury to an identifiable group of individual residents, the indirect effects of the injury must be considered as well in determining whether the State has alleged injury to a sufficiently substantial segment of its population. A State also has a quasi-sovereign interest in not being discriminatorily denied its rightful status within the federal system -- that is, in ensuring that the State and its general population are not excluded from the benefits that are to flow from participation in the federal system. Pp. 458 U. S. 600-608.
(b) Under the above principles, Puerto Rico's allegations that petitioners discriminated against Puerto Ricans in favor of foreign laborers falls within the Commonwealth's quasi-sovereign interest in the general wellbeing of its citizens. A State's interest in the wellbeing of its residents, which extends beyond mere physical interests to economic and commercial interests, also includes the State's substantial interest in securing its residents from the harmful effects of discrimination. This interest is peculiarly strong in the case of Puerto Rico simply because of the fact that invidious discrimination frequently occurs along ethnic lines. Alternatively, Puerto Rico has "parens patriae" standing to pursue its residents' interests in the Commonwealth's full and equal participation in the federal employment service scheme established by the laws involved here. Pp. 458 U. S. 608-610.
632 F.2d 365, affirmed.
WHITE, J., delivered the opinion of the Court, in which all other Members joined, except POWELL, J., who took no part in the decision of the case. BRENNAN, J., filed a concurring opinion, in which MARSHALL, BLACKMUN, and STEVENS, JJ., joined, post, p. 458 U. S. 610.
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