Farmer Brothers Coffee v. Workers’ Compensation Appeals Board

Rafael Ruiz (plaintiff) was injured while working for Farmer Brothers Coffee (Farmer Brothers) (defendant), and he filed a workers’-compensation claim. The California Labor Code defined an employee eligible to receive compensation as a person who is lawfully or unlawfully employed, including aliens. Farmer Brothers argued that Ruiz was not entitled to workers’-compensation benefits, because he was not legally authorized to work in the United States, alleging that Ruiz had provided a false Social Security card and green card to obtain employment and had used the false Social Security number on his workers’-compensation claim form. Farmer Brothers argued that the language in the statute regarding unlawfully employed applied only to situations in which the employer was guilty of illegally hiring a worker, not to situations in which the employee violated the law by using fraudulent documents, because an employee should not be able to benefit from illegally gaining employment. Farmer Brothers further argued that Ruiz’s use of a false Social Security card and green card violated the California Insurance Code, which criminalized knowingly false or fraudulent material representations made to obtain workers’-compensation benefits and barred a claimant convicted of doing so from receiving benefits. However, Ruiz had not been convicted. The Workers’ Compensation Appeals Board found that Ruiz was an employee for workers’-compensation purposes and allowed his claim. Farmer Brothers appealed.