The U.S. Supreme Court’s review of Department of Labor v. Sun Valley Orchards, LLC is being closely watched by H-2A agricultural employers and immigration practitioners. The case could determine whether the U.S. Department of Labor (DOL) has the authority to use its administrative law judge (ALJ) and Administrative Review Board (ARB) processes to impose back wages and civil money penalties for alleged violations of H-2A employment requirements.
The case raises important constitutional and statutory questions about the role of federal administrative agencies in imposing monetary remedies on employers.
Supreme Court Review: What Is at Issue?
On April 27, 2026, the Supreme Court granted the DOL’s petition for review in Department of Labor, et al. v. Sun Valley Orchards, LLC. The Court limited its review to two primary questions.
First, the Court will consider whether Article III of the U.S. Constitution prevents DOL administrative law judges from imposing civil money penalties for alleged H-2A program violations because doing so infringes on the authority of Article III courts and the constitutional separation of powers.
Second, if the administrative process is constitutionally permissible, the Court will consider whether the Immigration and Nationality Act (INA) gives DOL the statutory authority to adjudicate and impose those monetary penalties.
The Supreme Court could resolve the case on constitutional grounds, statutory grounds, or a combination of both.
As of September 2, 2026, the Supreme Court docket had not identified a date for oral argument. The parties had submitted their merits briefs, and amicus briefs supporting both sides had also been filed.
Background of the Sun Valley Orchards Case
Sun Valley Orchards, a New Jersey agricultural operation, participated in the H-2A temporary agricultural worker program during the 2015 season. Its job order covered 96 H-2A workers and 51 workers in corresponding employment.
Following an investigation, DOL alleged several violations of the employer’s H-2A obligations. The allegations included issues involving:
- Worker housing
- Kitchen access and meal charges
- Improper deductions
- Transportation obligations
- The H-2A three-fourths guarantee
- Worker-departure documentation
After a four-day administrative hearing, the ALJ issued a decision on October 28, 2019, ordering Sun Valley Orchards to pay approximately $344,945.80 in back wages and $211,800 in civil money penalties.
The ARB subsequently affirmed the ALJ’s decision.
District Court and Third Circuit Proceedings
Sun Valley Orchards challenged the agency’s decision in the U.S. District Court for the District of New Jersey under the Administrative Procedure Act (APA).
The district court upheld DOL’s action. It concluded that the dispute fell within the public-rights doctrine and that the INA authorized DOL to impose the monetary remedies.
Sun Valley Orchards appealed to the U.S. Court of Appeals for the Third Circuit.
On July 29, 2025, a unanimous Third Circuit panel reversed the district court’s decision and directed that judgment be entered in favor of Sun Valley Orchards. The court subsequently denied rehearing on October 15, 2025.
DOL then petitioned the Supreme Court for review on February 12, 2026. The Supreme Court granted certiorari on April 27, 2026.
Why the Third Circuit Rejected DOL’s Administrative Process
The Third Circuit’s decision relied heavily on the Supreme Court’s 2024 decision in SEC v. Jarkesy, 603 U.S. 109 (2024).
The Third Circuit viewed the certified H-2A job order as creating contractual obligations between the agricultural employer and workers. From that perspective, the court characterized DOL’s allegations as claims involving breaches of those employment obligations.
The court also viewed the monetary remedies as legal relief.
In particular, the panel concluded that DOL’s civil money penalties were legal remedies. It also treated the back-wage award as involving a legal claim because DOL relied, at least in part, on deterrence rather than exclusively on compensating workers.
Based on these considerations, the Third Circuit concluded that the dispute implicated rights traditionally resolved through judicial proceedings and therefore fell within the protections of Article III.
What the Supreme Court Decision Could Mean for H-2A Employers
The Supreme Court’s decision could have significant consequences for employers participating in the H-2A program.
If the Court agrees with the Third Circuit, DOL may face restrictions on its ability to use internal administrative proceedings to impose monetary remedies for certain H-2A violations.
Depending on the scope of the ruling, DOL could potentially be required to bring monetary claims in an Article III federal court rather than resolving them through its ALJ and ARB system.
Such a decision could also affect how employers respond to DOL enforcement actions and how H-2A compliance disputes are litigated.
However, the ultimate impact will depend heavily on the reasoning adopted by the Supreme Court.
Current Effect of the Third Circuit Decision
For employers and practitioners in the Third Circuit, the Sun Valley Orchards decision remains binding circuit precedent unless it is stayed, vacated, or reversed by the Supreme Court.
Outside the Third Circuit, however, the decision is persuasive authority rather than controlling precedent.
Accordingly, employers outside the Third Circuit should not assume that DOL lacks authority to pursue monetary remedies through its administrative enforcement process. DOL regulations and enforcement procedures remain applicable unless superseded by controlling legal authority.
H-2A employers should therefore continue to take their regulatory obligations seriously and maintain appropriate records demonstrating compliance with applicable program requirements.
Possible Outcomes Before the Supreme Court
The Supreme Court has several potential paths for resolving the case.
1. The Court Could Affirm the Third Circuit
The Court could conclude that Article III requires certain H-2A monetary claims to be adjudicated in federal court rather than through DOL administrative proceedings.
Such a ruling could significantly limit the agency’s use of ALJs to impose monetary remedies.
2. The Court Could Rely on the INA
The Court could avoid or limit the constitutional question and instead determine that the INA does not give DOL authority to adjudicate and impose the disputed monetary remedies through its internal administrative process.
This could result in a narrower decision focused primarily on statutory authority.
3. The Court Could Reverse the Third Circuit
The Supreme Court could determine that the disputed H-2A enforcement actions fall within the public-rights doctrine or otherwise constitute matters that Congress may authorize an administrative agency to resolve.
Such a ruling could preserve DOL’s existing administrative enforcement framework.
4. The Court Could Issue a More Limited or Mixed Decision
The Court could distinguish between different types of monetary remedies or H-2A obligations.
For example, the Court could treat civil penalties differently from compensatory back wages, or distinguish contractual employment obligations from regulatory requirements. It could also differentiate monetary penalties from other H-2A program sanctions.
The precise reasoning will determine how broadly the decision applies.
Potential Impact Beyond the H-2A Program
The significance of Sun Valley Orchards may extend beyond agricultural immigration.
If the Supreme Court restricts an agency’s ability to use ALJs and internal administrative review boards to impose monetary penalties or other legal remedies, the decision could have implications for other federal agencies and regulatory programs.
A broad ruling could require agencies to bring certain monetary claims in federal court, potentially involving Article III judges and, where applicable, jury proceedings.
It could also change the way employers challenge agency enforcement actions that previously proceeded through administrative adjudication and internal appeals before reaching federal court.
At the same time, the scope of any broader impact will depend on how the Supreme Court analyzes the statutory authority, historical practice, nature of the asserted rights, and type of remedy involved in the case.
What H-2A Employers Should Do Now
Until the Supreme Court issues its decision, H-2A employers should continue complying with existing DOL requirements.
Employers should pay particular attention to areas that commonly generate compliance concerns, including worker housing, transportation, wage payments and deductions, the three-fourths guarantee, meals, and required documentation.
Employers should also maintain detailed records supporting compliance with H-2A obligations. Proper documentation can be especially important when responding to a DOL investigation or enforcement proceeding.
The pending Supreme Court case should not be viewed as eliminating existing H-2A responsibilities. The legal framework remains in effect while the Court considers the scope of DOL’s enforcement authority.
Looking Ahead
The Supreme Court’s decision in Department of Labor v. Sun Valley Orchards, LLC could become an important development in H-2A employer compliance and federal administrative enforcement.
For H-2A employers, the case raises a fundamental question: Can DOL impose monetary remedies through its own administrative adjudication system, or must certain claims be decided by an Article III federal court?
The answer could affect how DOL conducts H-2A enforcement actions and potentially influence administrative enforcement practices in other federal programs.
Employers and immigration professionals should continue monitoring the Supreme Court docket and subsequent decisions for developments that could affect H-2A compliance, enforcement proceedings, and available avenues for challenging agency monetary assessments.
Immigration Fleet Law Firm