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Keywords

subpoenacompliancerespondentrelevance
subpoenaappealcomplianceobjectionoverruledrespondentrelevance

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Seasonal AG Services, Inc.; Administrator, Wage and Hour Division v.

Facts

The petitioner initiated an investigation into JY Harvesting, Inc. after a serious automobile accident involving a van owned by the respondent, which resulted in multiple injuries and the death of a seasonal agricultural worker. Following the accident, the Wage and Hour Division of the Department of Labor issued an administrative subpoena for documents related to the investigation. The respondents provided some documents but claimed they had no further responsive documents for certain requests, leading to the petition for enforcement.

Petitioner began an administrative investigation of Respondents following a very serious automobile accident that caused multiple serious injuries and the death of a seasonal agricultural worker. On March 15, 2017, a 2002 Chevy Express Van, owned by Respondent Pinedo, was supplied to Fernando Pinedo Garcia, doing business as Healthy Harvesting, to transport seasonal agricultural workers. While traveling, a tire catastrophically failed causing the van to roll numerous times. The California Highway Patrol referred the accident to the Wage and Hour Division of the United States Department of Labor ('Wage and Hour').

Issue

Whether the court should enforce the administrative subpoena duces tecum issued to JY Harvesting, Inc. and Jose Jesus Pinedo for documents related to the investigation of compliance with the Migrant and Seasonal Agricultural Worker Protection Act.

Whether the court should enforce the administrative subpoena duces tecum issued to JY Harvesting, Inc. and Jose Jesus Pinedo for documents related to the investigation of compliance with the Migrant and Seasonal Agricultural Worker Protection Act.

Rule

The court applied the standard that an administrative subpoena should be enforced if the agency has the authority to investigate, procedural requirements have been followed, and the evidence sought is relevant and material to the investigation.

The Ninth Circuit Court of Appeals has explained that '[t]he scope of the judicial inquiry in [] any [] agency subpoena enforcement proceeding is quite narrow. The critical questions are: (1) whether Congress has granted the authority to investigate; (2) whether procedural requirements have been followed; and (3) whether the evidence is relevant and material to the investigation.' E.E.O.C. v. Federal Exp. Corp. , 558 F.3d 842, 848 (9th Cir. 2009) (internal quotation omitted). 'If these factors are shown by the agency, the subpoena should be enforced unless the party being investigated proves the inquiry is unreasonable because it is overbroad or unduly burdensome.'

Analysis

The court found that the respondents did not dispute the authority of the Secretary of Labor to investigate or the procedural compliance of the subpoena. The respondents also did not claim that the evidence sought was irrelevant or unduly burdensome. Given these factors, the court determined that the subpoena should be enforced, as the petitioner demonstrated the relevance of the requested documents to the investigation.

Petitioner claims that Respondents' responses to Requests Nos. 3, 4, and 6 are deficient. Petitioner also claims that Respondents have lodged an improper objection to Request No. 7. Respondents do not dispute that Congress has granted Wage and Hour authority to investigate nor do they contend that Petitioner failed to follow the procedural requirements. Respondents also do not claim the evidence sought is irrelevant, overboard, or unduly burdensome.

Conclusion

The court granted the petition to enforce the administrative subpoena, ordering the respondents to produce the requested documents by August 25, 2017. The court cautioned that failure to comply could result in sanctions.

Since Respondents do not contest the authority of Petitioner, do not claim Petitioner failed to follow the procedural requirements, do not claim the evidence sought is irrelevant, overboard, or unduly burdensome, the Court ORDERS as follows: 1. Respondents' objection to Request No. 7 is OVERRULED . 2. Petitioner's application for an order to enforce the subpoena issued is GRANTED.

Who won?

Petitioner R. Alexander Acosta prevailed in the case because the court found that the respondents did not contest the authority or relevance of the subpoena, leading to the enforcement of the subpoena.

Petitioner R. Alexander Acosta prevailed in the case because the court found that the respondents did not contest the authority or relevance of the subpoena, leading to the enforcement of the subpoena.

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