Alfred L. Snapp & Son, Inc. v. Puerto Rico Ex Rel. Barez

458 U.S. 592 · 1982

Facts

The Wagner-Peyser Act and the Immigration and Nationality Act established a federal employment system to provide domestic workers preference and prevent discrimination by employers needing temporary foreign laborers. Employers must first seek domestic workers through an interstate clearance system, offering them comparable benefits. In 1978, for the east coast apple harvest, 2,318 job openings were transmitted to Puerto Rico. The Commonwealth recruited Puerto Rican workers, but only 992 arrived on the mainland, with remaining flights cancelled due to alleged refusal by growers to employ them. Many who arrived were refused employment or dismissed shortly after for alleged unproductivity.

Issue

The legal question is whether the Commonwealth of Puerto Rico has standing to maintain a suit as parens patriae against apple growers for alleged violations of federal law. These violations purportedly discriminated against Puerto Rican workers and injured the Puerto Rican economy, despite the relatively small number of individuals directly involved.

Holding

The Court held that Puerto Rico does have standing to maintain the parens patriae action. It found that the alleged discrimination against Puerto Ricans and the denial of access to domestic work opportunities fell within the Commonwealth's quasi-sovereign interests. The Court affirmed the Court of Appeals' decision, allowing the suit to proceed.

Rule

To maintain a parens patriae action, a state must assert an injury to a "quasi-sovereign" interest, distinct from private or proprietary interests, and be more than a nominal party. These interests include the health and well-being (physical and economic) of its residents in general, and ensuring the state is not discriminatorily denied its rightful status within the federal system. The injury must affect a sufficiently substantial segment of the population, considering indirect effects, and be the kind of injury the state would likely address through its sovereign lawmaking powers. A state has a substantial interest in protecting its residents from discrimination and ensuring they receive the full benefits of federal laws.

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