Martinez-Rodriguez v. Giles, 391 F. Supp. 3d 985

Six Mexican veterinarians with professional degrees accepted job offers from Funk Dairy to enter the U.S. on NAFTA TN visas, expecting animal-science roles, specified pay/benefits, and assistance with housing/transportation.
Giles (dairy manager) recruited, interviewed, provided letters to the State Department, and plaintiffs met with counsel for visa interviews. Some coaching by counsel (e.g., not saying they would milk cows) occurred.
After arrival, plaintiffs mainly performed manual dairy work, allege reduced/erratic pay and charges for housing/transport, monitoring and controlling conduct by supervisors, and threats referencing deportation. Three plaintiffs quit; three were later terminated.
Plaintiffs sued under the Trafficking Victims Protection Reauthorization Act (18 U.S.C. §§ 1589, 1590, 1595) for forced labor and trafficking, plus six Idaho state-law claims. Defendants moved for summary judgment; court heard argument and took motions under advisement.
The district court found disputed facts but concluded plaintiffs failed to show defendants knowingly obtained or retained labor "by means of" threats or serious harm; granted summary judgment on federal claims and declined supplemental jurisdiction, dismissing state claims without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants violated 18 U.S.C. § 1589 (forced labor)	Funk Dairy recruited plaintiffs under false pretenses and used threats (including deportation) and abusive conditions to coerce continued labor	Conduct was at-will employment, at most a bad/employer, and alleged statements were lawful warnings or non-compelling; plaintiffs could and did leave	Summary judgment for defendants: plaintiffs failed to show requisite scienter or that threats/conditions compelled them to remain under §1589
Whether defendants violated 18 U.S.C. § 1590 (trafficking into servitude)	Recruitment and misrepresentations constituted knowing trafficking into servitude	§1590 requires a predicate TVPRA offense (e.g., §1589); absent forced labor claim, §1590 fails	Summary judgment for defendants: §1590 fails because plaintiffs did not prove a §1589 violation
Admissibility/exclusion of plaintiffs' expert disclosure	Plaintiffs relied on expert Medige to support claims	Defendants moved to strike/exclude expert disclosure	Motion to strike was rendered moot by summary judgment on federal claims
Supplemental jurisdiction over state-law claims (fraud, contract, tort)	Plaintiffs sought to keep state claims in federal court	Defendants argued dismissal of federal claims would divest the court of supplemental jurisdiction	Court declined to exercise supplemental jurisdiction and dismissed state claims without prejudice

Zetwick v. County of Yolo, 850 F.3d 436 (9th Cir. 2017) (summary judgment standard and viewing facts in nonmoving party's favor)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (party with burden must present evidence of essential elements at trial to avoid summary judgment)
Far Out Productions, Inc. v. Oskar, 247 F.3d 986 (9th Cir. 2001) (unsworn statements insufficient to defeat summary judgment)
United States v. Dann, 652 F.3d 1160 (9th Cir. 2011) (interpreting §1589 scienter and "by means of" requirement)
Headley v. Church of Scientology Int'l, 687 F.3d 1173 (9th Cir. 2012) (distinguishing abusive conditions from obtaining labor "by means of" threats or coercion under TVPRA)
Muchira v. Al-Rawaf, 850 F.3d 605 (4th Cir. 2017) (totality of circumstances and victim vulnerabilities in forced labor analysis)
Calimlim v. Gonzales, 538 F.3d 706 (7th Cir. 2008) (forced labor conviction where long-term, extreme control and abuse compelled labor)