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Estados Unidos Mexicanos v. Decoster

Facts

Claims of deplorable working and living conditions for migrant workers at DeCoster Egg Farms, a large Maine employer, were made in a civil rights action filed in May of 1998. The thrust of the complaint was that workers of Mexican descent, be they American or Mexican citizens, were treated harshly because of their Mexican background, and that white, non-Mexican workers fared better. The primary cause of action asserted violations of the workers' civil rights under 42 U.S.C. 1981. The complaint also asserted other claims, including claims of unsafe and unsanitary housing under the Migrant and Seasonal Agricultural Worker Protection Act, 29 U.S.C. 1801 et seq. The complaint was filed by fourteen individuals, who proposed to represent a class of 'all former and current migrant farm workers of Mexican race and descent' employed by Austin J. DeCoster and DeCoster Egg Farm.

Claims of deplorable working and living conditions for migrant workers at DeCoster Egg Farms, a large Maine employer, were made in a civil rights action filed in May of 1998. The thrust of the complaint was that workers of Mexican descent, be they American or Mexican citizens, were treated harshly because of their Mexican background, and that white, non-Mexican workers fared better. The primary cause of action asserted violations of the workers' civil rights under 42 U.S.C. 1981. The complaint also asserted other claims, including claims of unsafe and unsanitary housing under the Migrant and Seasonal Agricultural Worker Protection Act, 29 U.S.C. 1801 et seq. The complaint was filed by fourteen individuals, who proposed to represent a class of 'all former and current migrant farm workers of Mexican race and descent' employed by Austin J. DeCoster and DeCoster Egg Farm.

Issue

The question here presented is whether a foreign nation which asserts only quasi-sovereign interests and not its own proprietary or sovereign interests should be afforded standing as parens patriae.

The question here presented is whether a foreign nation which asserts only quasi-sovereign interests and not its own proprietary or sovereign interests should be afforded standing as parens patriae.

Rule

Parens patriae means literally 'parent of the country.' The doctrine has developed as to States of the United States. It creates an exception to normal rules of standing applied to private citizens in recognition of the special role that a State plays in pursuing its quasi-sovereign interests in 'the well-being of its populace.'

Parens patriae means literally 'parent of the country.' The doctrine has developed as to States of the United States. It creates an exception to normal rules of standing applied to private citizens in recognition of the special role that a State plays in pursuing its quasi-sovereign interests in 'the well-being of its populace.'

Analysis

The court concluded that parens patriae standing should not be recognized in a foreign nation unless there is a clear indication of intent to grant such standing expressed by the Supreme Court or by the two coordinate branches of government. The justifications offered to support parens patriae standing in the individual States of the Union are not applicable here, and the court found that Mexico's claims did not meet the necessary standing requirements.

The court concluded that parens patriae standing should not be recognized in a foreign nation unless there is a clear indication of intent to grant such standing expressed by the Supreme Court or by the two coordinate branches of government. The justifications offered to support parens patriae standing in the individual States of the Union are not applicable here, and the court found that Mexico's claims did not meet the necessary standing requirements.

Conclusion

The dismissal of plaintiff Mexico's claims was affirmed because the federalism justifications that might permit states to bring suit parens patriae against private entities were absent.

The dismissal of plaintiff Mexico's claims was affirmed because the federalism justifications that might permit states to bring suit parens patriae against private entities were absent.

Who won?

The prevailing party was the defendants, as the court affirmed the dismissal of Mexico's claims for lack of standing.

The prevailing party was the defendants, as the court affirmed the dismissal of Mexico's claims for lack of standing.

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