Narrative Opinion Summary
The Ninth Circuit Court of Appeals considered an appeal involving Fowler Packing Company and Gerawan Farming, Inc., who challenged the constitutionality of carve-out provisions in California's Assembly Bill 1513 (AB 1513). These provisions were alleged to violate the Equal Protection Clause and the Bill of Attainder Clause of the U.S. Constitution. AB 1513 was enacted to address increased minimum wage liabilities and provided a safe harbor for employers making back payments. However, specific employers, including the plaintiffs, were excluded from these benefits due to ongoing litigation, which they argued was an unconstitutional targeting. The court found that the carve-outs potentially violated the Equal Protection Clause under rational basis review, and remanded the case for further proceedings on this claim. Conversely, the court affirmed the dismissal of the Bill of Attainder claim, as the carve-outs did not constitute punitive measures. The decision was thus partially affirmed and partially reversed, allowing the Equal Protection claim to proceed, while the district court's dismissal on the Bill of Attainder was upheld. Each party was ordered to bear its own costs.
Legal Issues Addressed
Bill of Attainder Clause under the U.S. Constitutionsubscribe to see similar legal issues
Application: The court upheld the district court's dismissal of the Bill of Attainder claim, determining that the carve-outs did not constitute punishment, which is necessary for such a claim.
Reasoning: The carve-outs do not impose punishment, thus rendering further examination of the other two elements unnecessary.
Equal Protection Clause Under the U.S. Constitutionsubscribe to see similar legal issues
Application: The court found that the carve-out provisions in AB 1513 appeared to target specific employers, preventing them from benefiting from a safe harbor provision, which raised a plausible violation of the Equal Protection Clause.
Reasoning: This rationale did not withstand rational basis scrutiny, allowing the plaintiffs to plausibly claim a violation of the Equal Protection Clause.
Rational Basis Review in Equal Protection Casessubscribe to see similar legal issues
Application: The court applied rational basis review to determine whether AB 1513's carve-outs had a legitimate governmental interest, which they found lacking, supporting a plausible equal protection claim.
Reasoning: The inquiry seeks any conceivable rational basis for the classification.
Safe Harbor Provisions in Labor Legislationsubscribe to see similar legal issues
Application: AB 1513 created a safe harbor for employers against claims of prior nonpayment, but included carve-outs that excluded certain employers from this provision due to ongoing litigation.
Reasoning: Employers can utilize the safe harbor provision by paying any minimum wage deficiencies from July 1, 2012, to December 31, 2015, by December 15, 2016, per Cal. Lab. Code. 226.2(b)(1)(A).