Arias-Villano v. Chang & Sons Enterprises, Inc., 118 N.E.3d 835

Defendants operate a year‑round, 44,000 sq. ft. hydroponic bean‑sprout facility; growing is largely automated in dedicated rooms.
Plaintiffs were production workers who cleaned, inspected, sorted, weighed, packaged sprouts, and cleaned the facility; they did not perform growing or harvesting.
Plaintiffs regularly worked over 40 hours/week (sometimes up to ~70) but were not paid overtime.
Plaintiffs sued under G. L. c. 151, § 1A, claiming unpaid overtime; defendants invoked the statutory agricultural exemption for "engaged in agriculture and farming on a farm."
The Superior Court granted summary judgment to defendants; the Supreme Judicial Court reviewed statutory interpretation de novo and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs’ sorting/packaging/cleaning work falls within the § 1A(19) "agriculture and farming" exemption	Work is post‑harvest/processing and thus outside the exemption	The exemption covers the defendants’ operations and should be interpreted broadly (analogous to FLSA)	Held for plaintiffs: exemption does not cover their post‑harvest packing/cleaning work
Proper textual definition of "agriculture and farming" in § 1A(19)	Use § 151, § 2 definition limiting to "growing and harvesting" and farm labor	Argue for adopting broader FLSA‑style definition	Held: apply G. L. c.151, § 2 definition (narrower), excluding postharvest activities
Role of legislative history in construing exemption	Legislative history supports narrow exemption enacted to protect farm workers while balancing employers’ needs	Legislative history does not mandate narrowing; FLSA analogy preferred	Held: history corroborates narrow construction of exemption to give effect to farm‑worker protections
Whether to adopt FLSA definition of "agriculture" for Massachusetts statute	Plaintiffs: Massachusetts statute differs and was meant to be broader for minimum wage but narrower for exemption; do not adopt FLSA	Defendants: federal definition is broader and should apply here	Held: court declines to adopt FLSA definition; Massachusetts text and legislative choices control

Mullally v. Waste Mgt. of Mass., 452 Mass. 526 (overtime statute purpose: reduce hours, encourage employment, compensate long workweeks)
Casseus v. Eastern Bus Co., 478 Mass. 786 (remedial statutes construed broadly; exemptions narrowly)
Wood v. Executive Office of Communities & Dev., 411 Mass. 599 (exemptions to remedial statutes are narrowly construed)
Boazova v. Safety Ins. Co., 462 Mass. 346 (summary judgment review and use of undisputed facts)
Boston Police Patrolmen's Ass'n v. Boston, 435 Mass. 718 (statutory‑interpretation principles)
Bulger v. Contributory Retirement Appeal Bd., 447 Mass. 651 (statutory definitions exclude unstated meanings)
Perez v. Bay State Ambulance & Hosp. Rental Serv., Inc., 413 Mass. 670 (interpretive principle about statutory definitions)
Swift v. AutoZone, Inc., 441 Mass. 443 (relationship between Massachusetts overtime law and FLSA)
Valerio v. Putnam Assocs. Inc., 173 F.3d 35 (comparison to federal law coverage)
Somerset v. Dighton Water Dist., 347 Mass. 738 (conjunctive statutory language should not be read disjunctively unless required)