Today the Massachusetts Supreme Judicial Court issued an important decision in favor of agricultural workers. The case is Arias-Villano et al. v. Chang & Sons Enterprises, Inc. which was brought on behalf of workers of a company farming and distributing bean sprouts. The key question in the case was whether the workers were entitled to overtime pay for their overtime hours worked.
While the Superior Court had decided in favor of the defendants, determining that the workers fell under the agricultural exemption and therefore could not receive overtime, the SJC, which was reviewing the case on appeal, overruled this decision.
This agricultural exemption applied to employees “engaged in agriculture and farming on a farm,” and so the key issue here, as SJC’s slip opinion underlined, was “the meaning of the phrase ‘agriculture and farming’”. To answer this question, the SJC turned to the legal definition of these terms, as established by M.G.L. c. 151, § 2: “labor on a farm and the growing and harvesting of agricultural, floricultural and horticultural commodities.”
This definition, the SJC pointed out, “does not include postharvesting activities.” This was essential to the case, because the plaintiffs “were not involved in the growing operations” of the beansprouts, “but instead cleaned, inspected, sorted, weighed, and packaged” them, as well as cleaning the facility and discarding waste. This work, the SJC wrote, “does not fall within the scope of the statute.” And, it pointed out, the history of the minimum wage and overtime statutes indicates that the agricultural exemption was meant to be applied narrowly, as here.
The SJC remanded the case to the Superior Court, granting the plaintiffs’ motion for summary judgment and overruling the grant of the defendants’ motion.
This is a big win for agricultural workers when it comes to wage law in Massachusetts. We are likely to see many more cases brought on behalf of workers like these who were involved in “postharvesting activities” rather than in the literal farming of a crop. The case means that these workers, who worked as many as seventy hours a week, and others like them logging hundreds of hours a month in the agricultural industry, can receive the overtime pay they have earned.
If you are an agricultural worker engaged in “postharvesting activities” who is not being paid overtime rates for your overtime hours worked, feel free to reach out to us.