De Canas et al. v. Bica et al.
424 U.S. 351 (1976)
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Rule of Law:
A state law that prohibits the knowing employment of aliens not entitled to lawful residence in the United States is not automatically unconstitutional as a regulation of immigration, nor is it preempted by the federal Immigration and Nationality Act (INA), as such a law represents a valid exercise of the state's traditional police power to regulate employment.
Facts:
- California enacted Labor Code § 2805(a), which prohibited employers from knowingly employing an alien not entitled to lawful residence if it would have an adverse effect on lawful resident workers.
- A group of migrant farmworkers, led by De Canas, were employed by farm labor contractors, including Bica.
- Bica and other contractors knowingly employed aliens who were not lawfully admitted to residence in the United States.
- This hiring practice resulted in a surplus of available labor.
- Due to this labor surplus, the contractors refused to continue employing De Canas and the other migrant farmworkers.
Procedural Posture:
- A group of migrant farmworkers (petitioners) sued several farm labor contractors (respondents) in California Superior Court, a state trial court.
- The Superior Court dismissed the complaint, holding that California Labor Code § 2805 was unconstitutional because it interfered with the federal government's exclusive power over immigration.
- The petitioners appealed to the California Court of Appeal, an intermediate appellate court.
- The Court of Appeal affirmed the trial court's dismissal, agreeing that the state law was an unconstitutional regulation of immigration and was preempted by the federal Immigration and Nationality Act (INA).
- The petitioners' request for review was denied by the Supreme Court of California, the state's highest court.
- The U.S. Supreme Court granted the petitioners' writ of certiorari to hear the case.
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Issue:
Is a state law that prohibits employers from knowingly employing an alien who is not entitled to lawful residence in the United States unconstitutional on the grounds that it is a regulation of immigration or is preempted by the federal Immigration and Nationality Act (INA)?
Opinions:
Majority - Mr. Justice Brennan
No. A state law prohibiting the knowing employment of aliens not entitled to lawful residence is not an unconstitutional regulation of immigration and is not necessarily preempted by the Immigration and Nationality Act (INA). The Court reasoned that while the power to regulate immigration is an exclusive federal power, not every state law that deals with aliens constitutes a regulation of immigration. The California statute is an exercise of the state's police power to regulate employment conditions within its borders, not a determination of who may be admitted into or remain in the country. The Court found no 'clear and manifest purpose of Congress' in the INA to completely oust state authority in this area. Furthermore, other federal statutes, like the Farm Labor Contractor Registration Act, expressly contemplate supplemental state action, indicating Congress did not intend to exclusively occupy the field of regulating the employment of aliens.
Analysis:
This decision clarifies that federal preemption in the immigration field is not absolute, drawing a crucial distinction between the exclusive federal power to control immigration (admission and deportation) and a state's concurrent power to regulate local matters like employment, even when those regulations affect aliens. The ruling provides a constitutional basis for states to enact laws aimed at curbing the employment of unauthorized immigrants to protect their local labor markets and economies. The case establishes that such state laws are permissible unless they are found to be a regulation of immigration in their application or directly conflict with federal law, setting the stage for future legal battles over state-level immigration-related legislation.
