Agricultural Employers Cite Jarkesy Precedent While Justice Department Defends Public Rights Doctrine
The Supreme Court heard oral arguments on November 10, 2026, in Sun Valley Orchards v. Department of Labor, a constitutional challenge to whether federal administrative law judges can assess civil monetary penalties against H-2A employers without a Seventh Amendment jury trial. The Supreme Court’s 2024 ruling in SEC v. Jarkesy invalidated the SEC’s in-house tribunals for securities fraud.
Sun Valley Orchards, a commercial fruit grower in southern New Jersey, sued after a Department of Labor administrative law judge assessed civil monetary penalties and back-wage restitution for alleged violations of guestworker housing and recruitment standards. Its counsel argued back-pay remedies mirror traditional common-law suits at law and entitle commercial enterprises to an Article III jury trial. A Justice Department attorney defended the Department of Labor’s statutory authority, maintaining that the H-2A visa program is a conditional federal privilege designed to protect domestic wages and that administrative adjudications fall within the public-rights doctrine.
During two hours of questioning, conservative justices pressed whether Department of Labor enforcement distinguishes public administrative compliance from punitive common-law damages. Moderate conservative justices asked whether jury trials for every localized agricultural wage dispute would inundate district courts. Liberal justices warned of systemic fallout if the court broadly curtailed administrative enforcement across non-financial agencies; Justice Department filings said dismantling administrative tribunals would cripple oversight across thousands of agricultural workplaces.
The American Farm Bureau Federation urged the justices to curb agency overreach, arguing administrative law judges lack judicial independence and impose arbitrary penalties on family farm operators. The United Farm Workers and the Constitutional Accountability Center cautioned eliminating administrative enforcement would leave vulnerable guestworkers without practical legal protection against wage theft. A final decision is expected by late June 2027.
