Zambrano v. Reinert

From June to October 1999, Rene Zambrano (plaintiff) worked as a seasonal worker for Seneca Foods, Inc. (Seneca), a vegetable processor in Wisconsin. In April 2000, Zambrano filed a claim for unemployment-compensation benefits. Because Zambrano was a seasonal worker, the Wisconsin Department of Workforce Development (DWD) applied the Cannery Rule to determine whether Zambrano was eligible. The Cannery Rule provided that a seasonal fruit or vegetable processor was not eligible for unemployment-insurance benefits unless: (1) the individual was employed outside of the active processing season, (2) the individual was otherwise eligible for benefits under Wisconsin Statute section 108.04(4)(a), or (3) the individual earned over $200 at another job during a statutorily defined time period preceding the processing job. The DWD determined that Zambrano did not work outside the active processing season, that Zambrano was not otherwise eligible for benefits under section 108.04(4)(a), and that Zambrano did not earn over $200 from an employer other than Seneca during the relevant period. DWD therefore denied Zambrano’s claim for unemployment-compensation benefits. Zambrano sued DWD Secretary Jennifer Reinert (defendant), claiming that the Cannery Rule violated the When Due Clause of the Social Security Act (SSA), 42 U.S.C. § 503(a)(1); the Federal Unemployment Tax Act (FUTA), 26 U.S.C. § 3304(a)(10); and the Equal Protection Clause of the Constitution. The district court granted summary judgment in favor of Reinert. Zambrano appealed.