Date: 1 July 1982
Court: Supreme Court of the United States
Citation: 458 U.S. 592
Short summary
The United States Supreme Court held that a State can establish standing to bring suit under the doctrine of parens patriae when its quasi-sovereign interests have been injured. Quasi-sovereign interests include those interests that the State has in the health and well-being – both physical and economic – of its citizens. When Virginia farmers discriminated against Puerto Rican farmworkers in violation of federal statute, Puerto Rico alleged an injury sufficient to establish parens patriae standing.
Summary by: Sara Sam-Njogu
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Weight of decision
Given the jurisdiction of the US Supreme Court, this decision is significant for States, and potentially other countries, that wish to establish standing when a large segment of their population has been physically and/or economically harmed.
Key facts
Respondent was the Commonwealth of Puerto Rico, which sued several apple farmers in the state of Virginia. Puerto Rico contended that despite a substantial advertised need for temporary farm laborers to pick the large 1978 apple crop, its farmworkers had been improperly refused employment based upon their Puerto Rican citizenship, illegal discrimination under several federal laws. Many of the workers were advised by the US Department of Labor not to travel to Virginia because growers were refusing to employ the workers who had already arrived, and those who had been employed were dismissed quickly for alleged unproductivity. The growers were hiring foreign workers instead. Puerto Rico sought to establish parens patriae standing because this discrimination invaded the Commonwealth’s interest in its citizens’ full and equal participation in the federal employment service scheme under the relevant federal laws.
Previous instances
In 1979, Puerto Rico filed suit in United States District Court for the Western District of Virginia (469 F.Supp. 928). While the court found that Puerto Rico may be capable of asserting parens patriae interests for some cases, it held that the relatively small number of farmworkers refused employment in this case – approximately 787 – meant that the injury was too small to Puerto Rico’s economy overall to establish standing.
On appeal, the Fourth Circuit reversed, holding that the District Court’s interpretation of the issue was too narrow (632 F.2d. 365). Instead, the proper focus was the “deliberate efforts to stigmatize the labor force as inferior,” conduct that would have an indirect effect on a substantial portion of Puerto Rico’s citizenry. It found the injury sufficient to establish parens patriae standing.
The Supreme Court granted certiorari, leading to the current holding.
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