Alfred L. Snapp & Son, Inc. v. Puerto Rico Ex Rel. Barez
73 L. Ed. 2d 995, 458 U.S. 592, 1982 U.S. LEXIS 154 (1982)
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Rule of Law:
A state has standing to sue as parens patriae when it asserts a quasi-sovereign interest, such as an interest in the health and economic well-being of its residents or an interest in ensuring its residents are not deprived of the benefits of the federal system.
Facts:
- A federal statutory framework, comprising the Wagner-Peyser Act and the Immigration and Nationality Act, establishes a system giving U.S. workers preference for temporary agricultural jobs over foreign workers.
- In 1978, a group of Virginia apple growers experienced a large harvest and sought temporary farm laborers through this federal system.
- The growers filed clearance orders for workers, and through the federal interstate system, job openings for 2,318 positions were transmitted to Puerto Rico.
- Puerto Rico's Department of Labor recruited workers to fill these positions, with 787 of the jobs being with the Virginia growers who are petitioners in this case.
- Of 992 recruited Puerto Rican workers who arrived on the mainland, 420 went to Virginia orchards.
- It is alleged that the Virginia growers refused to employ most of these workers and dismissed the others shortly after they started, for reasons of alleged unproductivity.
- Within three weeks of their arrival, fewer than 30 of the 420 workers sent to Virginia were still employed.
- Puerto Rico alleged the growers subjected these workers to burdensome conditions and discriminated against them in favor of temporary foreign workers from Jamaica.
Procedural Posture:
- The Commonwealth of Puerto Rico filed suit against numerous Virginia apple growers in the United States District Court.
- The apple growers filed a motion to dismiss, arguing that Puerto Rico lacked standing to bring the action as parens patriae.
- The District Court granted the motion to dismiss, concluding the number of individuals involved was too small to constitute an injury to Puerto Rico's general economy.
- Puerto Rico, as appellant, appealed the dismissal to the United States Court of Appeals for the Fourth Circuit.
- A divided panel of the Court of Appeals reversed the District Court, holding that Puerto Rico did have standing to maintain the suit.
- The apple growers, as petitioners, were granted a writ of certiorari by the United States Supreme Court.
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Issue:
Does the Commonwealth of Puerto Rico have standing as parens patriae to sue private employers for alleged violations of federal employment laws that discriminate against its residents and deny them work opportunities?
Opinions:
Majority - Justice White
Yes. Puerto Rico has standing to sue as parens patriae because it has articulated quasi-sovereign interests apart from the interests of the individual workers. A state's quasi-sovereign interests include protecting the health and well-being (both physical and economic) of its residents and ensuring that the state and its residents are not discriminatorily denied their rightful status and benefits within the federal system. Puerto Rico's allegations of discrimination against its residents and their exclusion from federal employment opportunities fall squarely within these categories. The court must consider the indirect effects of the injury, and the 'universal sting' of deliberate efforts to stigmatize a labor force as inferior is a cognizable injury to the state's quasi-sovereign interest in protecting its citizens from discrimination, regardless of the precise number of individuals directly harmed.
Concurring - Justice Brennan
Yes. The Court's reasoning is correct, but it should be emphasized that the standard for parens patriae standing in a district court is not as restrictive as it is for cases in the Supreme Court's original jurisdiction. A state's prerogative to bring suit in federal court to vindicate the federal rights of its citizens should be at least commensurate with that of a private organization, which can sue to protect its own institutional interests. As a sovereign entity, a state is entitled to assess its needs and decide which concerns of its citizens warrant its intervention, and a federal court should not superimpose its own judgment on the legitimacy of a state's asserted sovereign interest.
Analysis:
This decision clarifies and strengthens the modern doctrine of parens patriae standing by explicitly recognizing a state's quasi-sovereign interest in protecting its citizens from discrimination and ensuring their access to federal programs. The Court's focus on indirect effects and the 'universal sting' of discrimination broadens the concept of injury to the state itself, allowing for suits even where the direct economic impact or number of individuals affected might seem small relative to the total population. This precedent provides states a significant tool to combat systemic discrimination and enforce federal laws against private actors on behalf of their citizenry.
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