United Farm Workers of America v. Dutra Farms

The United Farmworkers of America, AFL-CIO, and associated individuals (UFW) sued appellants Dutra Farms and Clint Miller Farms, Inc., for unfair business practices and for violating Labor Code section 1155.4, subdivision (c) (hereafter section 1155.4(c)). 1 The UFW moved for summary judgment. The trial court granted the motion, entered judgment for the UFW, and declared that appellants violated section 1155.4(c). The court also enjoined appellant Clint Miller Farms from violating the statute in the future.

On appeal, the main issue is the applicability of section 1155.4(c). In essence, section 1155.4(c) prohibits agricultural employers from giving anything of value to employee groups for the purpose of causing such employee groups to influence other employees regarding their collective bargaining rights. Like the trial court, we conclude that section 1155.4 applies to these circumstances. We will therefore affirm.

Facts and Procedural Background

The undisputed facts are as follows.

In 1996, the UFW announced an ongoing campaign to organize strawberry pickers into a union. Subsequently, the “Pro Workers Committee” (PWC) was formed to oppose the UFW. Several Miller…