South Jersey family farm takes fight with Labor Department to Supreme Court

A fourth-generation South Jersey family farm ordered to pay more than $550,000 after a federal labor investigation will take its constitutional challenge to the U.S. Supreme Court this fall in a case that could determine how far federal agencies may go in imposing monetary penalties through their own administrative courts.

The us Supreme Court is scheduled to hear arguments Nov. 10 in Department of Labor v. Sun Valley Orchards, a dispute over whether the U.S. Department of Labor may adjudicate claims seeking monetary remedies from agricultural employers accused of violating conditions of the federal H-2A temporary worker program.

Sun Valley Orchards, a family-owned farm in the Swedesboro area, argues that the Constitution requires the government to bring its monetary claims before an independent federal court rather than before administrative judges employed by the Labor Department.

The dispute began after the Labor Department investigated the farm’s treatment of immigrants working under the H-2A agricultural visa program.

The Trump administration argued that the Department of Labor enforced requirements that allow an employer to “import an alien as an H–2A worker” if they get federal certification and agree to meet certain federal standards, including basic requirements for wages and working conditions.

The farm’s fight with federal officials was featured in the Harvard Law Review. 

In early 2016, federal officials notified Sun Valley that the department was seeking more than $550,000 in back wages and civil penalties. More than $320,000 of the government’s original demand stemmed from a single alleged violation, according to the farm.

Brothers Joseph and Russell Marino, whose family owns Sun Valley Orchards, disputed the government’s allegations. But their challenge initially remained within the same federal department that had brought the enforcement action.

The Labor Department ultimately found Sun Valley responsible for violations involving workers’ wages, housing, transportation and employment guarantees.

After a four-day administrative trial, a Labor Department administrative law judge found the farm owed $344,945.80 in back wages and $211,800 in civil penalties, for a total of $556,745.80.

The back wages were intended for 147 workers, including 96 temporary foreign workers employed under the H-2A program.

The Labor Department said Sun Valley failed to provide sanitary housing, transported workers using unsafe vehicles and unlicensed drivers, improperly terminated more than 20 workers during the growing season, and made unlawful deductions from workers’ wages for food and beverages.

During committee hearings when New Jersey enacted a state minimum wage increase, representatives from Sun Valley Orchards testified against the bill, arguing that fair wages would severely harm the state’s agricultural industry.

Sun Valley disputes the department’s account of the underlying events. But the case now before the Supreme Court focuses primarily on a different issue: who has the constitutional authority to decide whether the government is entitled to collect the money.

Farm challenges government’s in-house court

Sun Valley’s constitutional challenge strikes at a system of administrative adjudication used throughout the federal government.

Instead of filing its enforcement case against Sun Valley in U.S. District Court, the Labor Department proceeded through its administrative system.

An administrative law judge employed by the department presided over the hearing and issued a decision. Sun Valley then appealed to the Labor Department’s Administrative Review Board, which affirmed the decision in 2021.

The farm argues that the arrangement allowed the executive branch to act as investigator, prosecutor and adjudicator of claims seeking hundreds of thousands of dollars.

The Marino brothers subsequently turned to the federal courts.

Represented by the Institute for Justice, Sun Valley contends that Article III of the Constitution assigns the federal judicial power to independent courts whose judges are nominated by the president, confirmed by the Senate and protected by life tenure.

The farm argues that when the federal government seeks to compel a private party to pay substantial monetary remedies, it should generally be required to prove its case before an independent federal judge rather than an adjudicator working for the agency pursuing the money.

The Labor Department rejects that interpretation.

The government maintains that Congress authorized the department to administer and enforce the H-2A program and that administrative proceedings are a lawful means of enforcing obligations employers voluntarily assume when participating in the federal program.

The H-2A program allows agricultural employers facing shortages of domestic labor to employ foreign workers temporarily for seasonal agricultural jobs. Participating employers must comply with federal requirements governing wages, housing, transportation and other working conditions.

Appeals court sides with farm

Sun Valley’s constitutional argument initially failed in federal district court, but the Philadelphia-based 3rd U.S. Circuit Court of Appeals reversed that result in July 2025.

A unanimous three-judge panel ruled that the Labor Department could not constitutionally adjudicate the monetary claims against Sun Valley in its administrative tribunal.

The appeals court concluded that the dispute involved the exercise of judicial power that Article III generally reserves for federal courts.

The decision did not declare that the Labor Department could never pursue Sun Valley for alleged violations.

Instead, it addressed where such a dispute must be decided.

Under the 3rd Circuit’s reasoning, the government could seek monetary remedies, but it would have to pursue them in an independent federal court rather than obtain a binding monetary judgment through its own administrative process.

That distinction transformed a dispute involving one Gloucester County farm into a potentially significant case over the separation of powers.

The federal government appealed.

Supreme Court steps in

The Supreme Court agreed April 27 to hear the government’s appeal.

The justices limited their review to two questions.

The first asks whether Article III prevents the Labor Department from conducting administrative proceedings to collect monetary remedies from employers accused of violating employment conditions governing H-2A workers and domestic workers employed alongside them.

The second asks whether federal immigration law authorizes the department to adjudicate those monetary claims in the first place.

The case therefore presents both a constitutional question and a statutory one.

The distinction could matter considerably.

If the justices conclude that Congress never gave the Labor Department authority to decide such monetary claims administratively, they could resolve the dispute without deciding the broader constitutional limits on administrative adjudication.

But if the court reaches the Article III question, its reasoning could extend well beyond agriculture.

Federal agencies rely extensively on administrative proceedings to enforce laws and regulations. Administrative law judges and agency review boards hear disputes involving businesses and individuals in areas ranging from labor and securities regulation to environmental and workplace rules.

A broad ruling restricting administrative adjudication could alter how the federal government enforces some regulatory laws.

A dispute over workers — and government power

The government’s allegations against Sun Valley are serious.

Labor officials found that workers were subjected to improper wage deductions and inadequate living conditions and that some were transported in substandard vehicles by unlicensed drivers. The government also alleged that workers were denied employment guaranteed under H-2A rules.

The farm’s Supreme Court challenge does not necessarily require the justices to determine whether every underlying allegation was true.

Instead, the case asks who gets to make those determinations when the federal government seeks substantial monetary remedies.

That question places two competing principles before the court.

The government argues that administrative enforcement is an integral part of a federal program designed to protect vulnerable agricultural workers and ensure that employers receiving permission to hire temporary foreign workers comply with the conditions attached to that privilege.

Sun Valley argues that efficiency cannot override the Constitution’s separation of powers and that the government should not be permitted to impose major financial liability through a tribunal housed within the agency bringing the charges.

The dispute comes as the Supreme Court has increasingly examined the authority of administrative agencies and the constitutional limits separating executive agencies from federal courts.

For Sun Valley, however, the constitutional debate began not as an abstract dispute over administrative law but with a government demand that threatened a family agricultural business.

The farm has spent years contesting a judgment exceeding half a million dollars.

Now the dispute that began in the fields of South Jersey will be argued before the nation’s highest court.

When the justices hear Department of Labor v. Sun Valley Orchards on Nov. 10, the question before them will extend far beyond one farm and one federal investigation: When the government seeks to take hundreds of thousands of dollars from a private party, does the Constitution guarantee that party a hearing before an independent federal court?