Gaudencio Garcia-Celestino v. Consolidated Citrus Limited Partnership, 843 F.3d 1276

Plaintiffs were H-2A temporary Mexican harvest workers who worked for RHI (a labor contractor) on Consolidated Citrus groves during the 2007–08 and 2008–09 seasons; RHI recruited, transported, housed, and paid the workers on a piece-rate basis.
Consolidated Citrus scheduled which grove blocks to harvest, issued ID badges and ran the timekeeping system, supervised anti‑citrus‑canker procedures, and could halt harvesting, but day‑to‑day direction and discipline of the crews was performed by RHI.
RHI paid piece rates and its payroll software performed AEWR “build‑up” calculations; RHI (through Ruiz) ran a kickback scheme in which workers were coerced to return their build‑up pay in cash; Consolidated Citrus was unaware of the kickbacks.
Plaintiffs sued (FLSA, breach of H‑2A clearance‑order contracts, state wage claims, and earlier AWPA claims), RHI and Ruiz settled, and Consolidated Citrus remained the sole defendant for the FLSA and contract claims at trial.
The district court applied the expansive FLSA “suffer or permit to work” standard (via a 1987 DOL H‑2A regulation) to the breach‑of‑contract (H‑2A) claims and found Consolidated Citrus a joint employer; the Eleventh Circuit affirmed liability under the FLSA but held the common‑law agency standard governs breach‑of‑contract (H‑2A) claims and remanded for application of that standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Governing standard for H‑2A breach‑of‑contract (who is an “employer”)	DOL’s 1987 H‑2A regulation adopting the FLSA “suffer or permit to work” standard governs, so Consolidated can be a joint employer under the expansive standard	The INA/IRCA did not define “employer”; under Darden the common‑law agency definition governs absent a statutory definition	Common‑law agency principles govern H‑2A contract claims; the 1987 DOL regulation is not entitled to Chevron deference (reversed as to district court’s standard; remanded)
Joint‑employer status under the FLSA (minimum‑wage claims)	Plaintiffs: Consolidated is a joint employer under the Aimable/economic‑dependence test	Consolidated: even under the FLSA standard it is not a joint employer	Affirmed: Consolidated is a joint employer under the FLSA’s expansive “suffer or permit to work” standard
Deference to DOL 1987 regulation (Chevron)	DOL regulation should control for pre‑2009 seasons	Because Congress omitted a statutory definition, courts should apply common law per Darden; Congress did not adopt AWPA/FLSA definition in IRCA	Chevron step one: statutory text and context show Congress intended common law meaning; the 1987 regulation receives no deference

Nationwide Mut. Ins. Co. v. Darden, 503 U.S. 318 (establishes that where a statute uses a common term without defining it courts generally adopt the settled common‑law meaning)
Arriaga v. Fla. Pac. Farms, L.L.C., 305 F.3d 1228 (clearance orders function as enforceable H‑2A work contracts)
Aimable v. Long & Scott Farms, 20 F.3d 434 (economic‑dependence factors for FLSA joint‑employer analysis)
United States v. Rosenwasser, 323 U.S. 360 (describing breadth of the FLSA “suffer or permit to work” definition)
Chevron U.S.A., Inc. v. Nat. Res. Def. Council, Inc., 467 U.S. 837 (agency‑deference framework)
NLRB v. Town & Country Elec., Inc., 516 U.S. 85 (discusses deference where Congress intended agency to define terms)
NLRB v. Amax Coal Co., 453 U.S. 322 (canon that courts give common‑law meaning to undefined statutory terms)
Layton v. DHL Express (USA), Inc., 686 F.3d 1172 (enumerates factors and principles for joint‑employer analysis under FLSA)
Antenor v. D & S Farms, 88 F.3d 925 (AWPA/FLSA joint‑employer guidance cited by court)