Castillo v. Case Farms of Ohio, Inc.

Case Farms of Ohio, Inc. (Case Farms) (defendant) was a chicken-processing plant in Ohio. From 1996 to 1997, Case Farms actively recruited new employees. Andy Cilona, the Human Resources and Corporate Development Director for Case Farms, reached out to America’s Tempcorps (Tempcorps) to hire temporary employees for Case Farms. Tempcorps recruited and hired employees in Texas to work at the Case Farms chicken-processing plant in Ohio. Tempcorps made representations to the recruits about the housing conditions Case Farms would provide in Ohio. Tempcorps gave the recruits a free bus ticket to Ohio and $20 to cover other travel expenses. When the recruits arrived in Ohio they were placed in bare houses or apartments, slept on the floor, and in some instances shared the home with 17 other recruits. Many recruits encountered cockroaches and rats. The recruits were transported to and from work in overcrowded vans with wooden boards instead of seats. A group of Tempcorps recruits (plaintiffs) sued Case Farms under the Migrant and Seasonal Agricultural Worker Protection Act, which prohibited false representations concerning employment practices, housing conditions, and transportation arrangements for migrant and seasonal workers. The recruits alleged that the terms and conditions of employment in Ohio substantially differed from the promises Tempcorps made when Tempcorps hired the recruits. To support their claim, the recruits relied on a theory of agency, arguing that an agency relationship existed between Case Farms and Tempcorps.