Court weighs whether Department of Labor judges can impose heavy fines without juries

On November 10, the court will hear oral arguments in Department of Labor v. Sun Valley Orchards, LLC. The case focuses on the H-2A visa program for temporary immigrant workers and whether administrative law judges have the authority to collect large fines from employers who violate employment contracts.

An amicus brief filed in the case argues that respondents are entitled to a Seventh Amendment civil jury and an Article III federal court. The legal dispute centers on whether the government can condition the admission of foreign workers on employers surrendering their constitutional right to have employment disputes adjudicated in federal court with a jury.

The public-rights doctrine and federal penalties

The government relies on the public-rights doctrine to argue that immigration is a government-created privilege rather than a property right. Under this theory, privileges can be adjudicated by non-Article III judges without a Seventh Amendment jury trial. The government contends that Sun Valley’s conduct is not subject to Article III protections because immigration into the country is a privilege.

Critics of the government’s position point to the 1977 case Atlas Roofing Co. v. OSHA, which altered the public-rights doctrine by allowing administrative agencies to issue enforcement orders for new statutory obligations without a jury. However, a more recent 2024 decision in SEC v. Jarkesy held that when federal agencies impose civil penalties for fraud, the Seventh Amendment entitles the defendant to a jury trial because such cases would have been common-law actions in 1787.

What this means for employers and workers

This case addresses whether federal agencies can bypass standard court protections when penalizing employers. While the government holds sovereign authority to control immigration, the central question is whether that authority can be used to waive constitutional rights such as the Seventh Amendment.

For employers facing agency enforcement actions, the outcome could determine whether severe financial penalties can be assessed exclusively through administrative hearings or if corporations have a right to jury trials. Temporary workers and agricultural employers alike await clarity on how federal labor regulations are enforced.

Next steps for affected parties

Employers utilizing the H-2A visa program or facing administrative penalties should carefully monitor the proceedings as the court evaluates the boundaries of administrative law judge authority. Organizations navigating labor disputes may wish to consult legal counsel regarding how recent court precedents affect administrative enforcement actions and civil penalties.

This article is general information based on SCOTUSblog and court or agency records available at publication time. It is not legal advice; laws and deadlines differ by state and by case. Published November 6, 2026.