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Frank Diehl Farms v. Secretary of Labor
United States Court of Appeals for the Eleventh Circuit
696 F.2d 1325 (11th Cir. 1983)
Frank Diehl Farms and several other Florida farmers (defendants) provided temporary housing to seasonal migrant workers at little to no cost. The workers were not required to live in the housing, and the defendants did not depend on the workers to live in the housing in order to maintain an adequate labor supply. Any worker who lived in the housing was required to work on the farm where he or she lived whenever work was available, but was otherwise free to work for other employers. The Occupational Safety and Health Administration (OSHA) conducted an inspection of the temporary housing and found the housing to be in violation of standards set by the secretary of labor (plaintiff) pursuant to the Occupational Safety and Health Act (Act), 29 U.S.C. § 651 et seq. The Occupational Safety and Health Review Commission (OSHRC) ruled that the temporary housing was a workplace within the meaning and jurisdiction of the Act because the housing was directly related to employment. The defendants appealed, arguing that the temporary housing was outside the jurisdiction of the Act because the housing was not a condition of employment.
Rule of Law
Holding and Reasoning (Vance, J.)
Dissent (Johnson, J.)
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