United Farm Workers of America, Afl-Cio v. Arizona Agricultural Employment Relations Board

This case presents important issues of federalism arising out of the application of state labor law to a multistate agricultural employer. The Arizona Agricultural Employment Relations Board (Arizona Board) appeals from the district court’s order granting a preliminary injunction restraining a union representation election in Arizona among the employees of Bruce Church, Inc. (BCI). Because we find there was no legal basis justifying such equitable relief in this case, we vacate the injunction.

I

BCI, a California corporation, grows and harvests lettuce at four locations in California and two in Arizona. Approximately 90% of BCI’s agricultural employees work in both states at various times during the growing season. The remaining 10% work exclusively in Arizona. In 1976, the California Agricultural Labor Relations Board (California Board) determined that a single, statewide unit was appropriate for collective bargaining between BCI and its em ployees, “excluding those who work exclusively outside the State of California.” The California Board specifically found that it had no jurisdiction over labor matters occurring outside California and thus did not include BCI’s Arizona…