Respondents, migrant farmworkers employed by petitioner,
received benefits under Florida workers' compensation law for
injuries they suffered in an automobile accident while traveling to
work in petitioner's van. They subsequently filed suit against
petitioner in Federal District Court, alleging that their injuries
were attributable in part to petitioner's intentional violations of
the motor vehicle safety provisions of the Migrant and Seasonal
Agricultural Worker Protection Act (AWPA), 29 U.S.C. § 1801
et seq., and accompanying regulations. They sought actual
and statutory damages for such violations pursuant to AWPA's
private right of action provision, § 1854. The court granted
petitioner summary judgment on the ground that the state workers'
compensation law provides that its remedy is exclusive, and that
respondents' receipt of benefits under that law therefore precluded
them from recovering damages under AWPA for the same injuries. The
Court of Appeals reversed, holding that such an exclusivity
provision does not bar a private AWPA suit.
Held: Exclusivity provisions in state workers'
compensation laws do not bar migrant workers from availing
themselves of a private right of action under § 1854. Pp.
494 U. S.
642-651.
(a) The explicit language of AWPA's enforcement provisions --
which establishes a private right of action for "[a]ny person
aggrieved by a violation," § 1854(a) -- indicates that that
right is unaffected by the availability of remedies under state
workers' compensation law. A congressional intent to the contrary
is not established by AWPA's motor vehicle safety provisions, which
permit employers to satisfy the statute's insurance and liability
bond requirements through their state workers' compensation
insurance. The safety provisions appear in a Title far removed from
the enforcement provisions, and the latter provisions contain
Congress' sole express limitation on the availability of relief,
which applies where no attempt was made to resolve the disputed
issues before litigation. Had Congress intended to limit further
the availability of AWPA relief based on the adequacy of state
workers' compensation remedies, it would have made that purpose
clear in AWPA's enforcement provisions. Moreover, the insurance
waiver provision is not inconsistent with the availability of
overlapping remedies under workers' compensation
Page 494 U. S. 639
laws and AWPA, since the agricultural employer, whether or not
it has enrolled in a workers' compensation plan, will be liable
under AWPA's enforcement provisions if the employee's actual
damages exceed the required minimum insurance coverage. Although
Congress may choose to establish state remedies as adequate
alternatives to federal relief, it cannot be assumed that private
federal rights of action are conditioned on the unavailability of
state remedies absent some indication to that effect. Cases in
which this Court has harmonized federal statutes that provide
overlapping federal remedies are not to the contrary. Pp.
494 U. S.
643-647.
(b) AWPA preempts state law to the limited extent that it does
not permit States to supplant, rather than to supplement, the
statute's remedial scheme. Section 1871 -- which provides that
AWPA
"is intended to supplement State law, and compliance with [the
statute] shall not excuse any person from compliance with
appropriate State law and regulation"
-- does not require this Court to give effect to the Florida
exclusivity provision, even if that provision were intended to
withdraw AWPA's private right of action. Although § 1871
permits States to supplement the statute's remedial scheme, it
cannot be viewed as authorizing them to replace or supersede AWPA
remedies. Petitioner's claim that Congress intended to preserve the
particular balance state workers' compensation laws generally
strike between assurance of compensation and limited and exclusive
employer liability is off target, since the fact that AWPA may
affect that balance does not suggest that Congress intended AWPA's
remedial provisions to be effective only in certain States. Federal
law applies in all States, and the scope of federal law is not
curtailed where it conflicts with the policies purportedly
underlying some state regulatory schemes. State exclusivity
provisions that attempt to withdraw federal remedies directly
conflict with the federal scheme's purposes, and cannot be viewed
as permissible interstitial regulation. Pp.
494 U. S.
647-649.
(c) Even if AWPA's language establishing a private right of
action is ambiguous as to the statute's preemptive scope, this
Court need not defer to the Department of Labor's position that
state workers' compensation benefits, where applicable, are the
exclusive remedy for loss under the statute. Congress expressly
established the Judiciary, and not the Department, as the
adjudicator of AWPA private rights of action, and the Department's
statutory authorization to promulgate motor vehicle safety
standards cannot bootstrap that agency into an area in which it has
no jurisdiction. Pp.
494 U. S.
649-650.
867 F.2d 1305, affirmed.
MARSHALL, J., delivered the opinion for a unanimous Court.
Page 494 U. S. 640
JUSTICE MARSHALL delivered the opinion of the Court.
In this case, we must decide whether exclusivity provisions in
state workers' compensation laws bar migrant workers from availing
themselves of a private right of action under the Migrant and
Seasonal Agricultural Worker Protection Act (AWPA), 96 Stat. 2583,
as amended, 29 U.S.C. § 1801
et seq. (1982 ed. and
Supp. V). We hold that they do not.
I
Respondents, migrant farmworkers employed by petitioner Adams
Fruit Company, Inc., suffered severe injuries in an automobile
accident while they traveled to work in Adams Fruit's van. As a
result of their injuries, respondents received benefits pursuant to
Florida workers' compensation law. They thereafter filed suit
against Adams Fruit in Federal District Court, alleging that their
injuries were attributable in part to Adams Fruit's intentional
violations of AWPA's motor vehicle safety provisions, 29 U.S.C.
§ 1841(b)(1)(A) (1982 ed.), and accompanying regulations,
29
Page 494 U. S. 641
CFR § 500.105 (1989). Respondents maintained that the van
in which they were transported was inadequate to support the
vehicle's weight; that the total number of persons in the van
exceeded its seating capacity; that a seat was not provided for
each passenger; that the van was overloaded; that the seats in the
van were not equipped with seat belts; and that Adams Fruit
committed these violations intentionally. Respondents sought actual
and statutory damages pursuant to AWPA's private right of action
provision, 29 U.S.C. § 1854 (1982 ed.). [
Footnote 1]
Adams Fruit moved for summary judgment on the ground that
Florida law provides that its workers' compensation remedy "shall
be exclusive and in place of all other liability of such employer
to . . . the employee," Fla.Stat. § 440.11 (1989), and that
respondents' receipt of workers' compensation benefits therefore
precluded them from recovering damages under AWPA for the same
injuries. In support of its position, Adams Fruit maintained that
Congress did not, in creating a private right of action for migrant
workers, intend to preempt or interfere with the operation of state
workers' compensation schemes, including their exclusivity
provisions. The District Court granted petitioner's motion, relying
on the Fourth Circuit's decision in
Roman v. Sunny
Slope
Page 494 U. S. 642
Farms, Inc., 817 F.2d 1116, 1118 (1987). The Court of
Appeals for the Eleventh Circuit reversed, holding that an
exclusivity provision in a state workers' compensation law does not
bar a private suit under AWPA. 867 F.2d 1305, 1311 (1989). We
granted certiorari to resolve this split in authority, 493 U.S. 808
(1989), and now affirm.
II
Section 1854 of AWPA establishes a private right of action for
aggrieved migrant workers against agricultural employers, and
provides for actual and statutory damages in cases of intentional
violations. Resolution of petitioner's claim that AWPA's private
right of action is withdrawn where state law establishes workers'
compensation as an exclusive remedy depends on two doctrinally
related issues. First we must decide whether, as a matter of
statutory construction, AWPA permits migrant workers to pursue
federal remedies under such circumstances. Second, if AWPA permits
simultaneous recovery under federal and state law, we must
determine whether, under preemption principles, AWPA precludes
giving effect to state exclusivity provisions that purport to
withdraw federal remedies. In either case, the issue turns on the
language of the statute and, where the language is not dispositive,
on the intent of Congress as revealed in the history and purposes
of the statutory scheme.
See, e.g., Consumer Product Safety
Comm'n v. GTE Sylvania, Inc., 447 U.
S. 102,
447 U. S. 108
(1980) ("[T]he starting point for interpreting a statute is the
language of the statute itself");
Shaw v. Delta Air Lines,
Inc., 463 U. S. 85,
463 U. S. 95
(1983) ("[I]n deciding whether a federal law preempts a state
statute, our task is to ascertain Congress' intent in enacting the
federal statute at issue"). As a general rule of statutory
construction, where the terms of a statute are unambiguous,
judicial inquiry is complete.
See, e.g., Rubin v. United
States, 449 U. S. 424,
449 U. S. 430
(1981). Preemption "is compelled whether Congress' command is
explicitly stated in the statute's
Page 494 U. S. 643
language or implicitly contained in its structure and purpose."
Jones v. Rath Packing Co., 430 U.
S. 519,
430 U. S. 525
(1977).
A
The enforcement provisions of AWPA that establish a private
right of action for "[a]ny person aggrieved by a violation" of the
Act's provisions or accompanying regulations, 29 U.S.C. §
1854(a) (1982 ed.), in no way intimate that the availability of
that right is affected by state workers' compensation law. Adams
Fruit nevertheless contends that the language of AWPA's enforcement
provisions is not dispositive, because other provisions of the
statute reflect congressional intent to withdraw private rights of
action where state workers' compensation is available.
Adams Fruit's argument focuses on § 1841, which concerns
motor vehicle safety. Subsections (a) and (b) of § 1841
establish minimum standards, licensing, and insurance requirements
to help secure safe transportation for migrant and seasonal
agricultural workers. As part of these protections, subsection
(b)(1)(C) requires each agricultural employer to
"have an insurance policy or a liability bond . . . which
insures the agricultural employer . . . against liability for
damage to persons or property arising from the ownership,
operation, or the causing to be operated, of any vehicle used to
transport any migrant or seasonal agricultural worker."
Subsection (c) waives this insurance requirement where an
agricultural employer "is the employer of any migrant or seasonal
agricultural worker for purposes of a State workers' compensation
law." In such cases, "[n]o insurance policy or liability bond [is]
required of the employer" if the migrant workers are transported
solely under circumstances for which there is coverage under such
state law.
Adams Fruit maintains that Congress' decision to permit
agricultural employers to satisfy AWPA's insurance policy and
liability bond requirements through their state workers'
compensation insurance reflects an intent to preclude AWPA
Page 494 U. S. 644
liability for bodily injury where employers have obtained
coverage under state law. In Adams Fruit's view, it would be
incongruous for Congress explicitly to waive insurance coverage
requirements where workers' compensation is available and at the
same time to allow migrant workers to seek cumulative remedies
under workers' compensation laws and AWPA. So construed, Adams
Fruit argues, the statute creates a trap for the unwary
agricultural employer, who reasonably could have expected the
waiver of insurance requirements to reflect a waiver of liability
as well.
Adams Fruit's argument is unpersuasive, because it rests on the
extraordinary and unjustified proposition that congressional intent
regarding private enforcement of AWPA is best discerned through a
meaning alleged to be implicit in AWPA's motor vehicle safety
provisions, rather than the explicit language of AWPA's enforcement
provisions. AWPA's motor vehicle safety provisions appear in Title
IV of the Act, entitled "Further Protections for Migrant and
Seasonal Agricultural Workers," whereas AWPA's provision for a
private right of action appears in Title V, part A, labeled
"Enforcement Provisions." Moreover, Congress' sole express
limitation on the availability of relief is found in AWPA's
enforcement provisions,
see § 1854(c)(2) (authorizing
a court, "[i]n determining the amount of damages to be awarded . .
to consider whether an attempt was made to resolve the issues in
dispute before the resort to litigation"). Had Congress intended to
limit further the availability of AWPA relief based on the adequacy
of state workers' compensation remedies, it would have made that
purpose clear in the enforcement provisions of AWPA. [
Footnote 2] Petitioner's argument,
Page 494 U. S. 645
which relies on provisions far removed from Congress' express
authorization of a federal remedy, is inconsistent with basic
principles of statutory construction that require giving effect to
the meaning and placement of the words chosen by Congress.
See
Davis v. Michigan Dept. of Treasury, 489 U.
S. 803,
489 U. S. 813
(1989).
Adams Fruit's argument is also flawed in that the insurance
waiver provision is not inconsistent with the availability of
overlapping remedies under workers' compensation laws and AWPA. It
is true that, in accordance with § 1841(c)(1)'s waiver of
insurance requirements, an agricultural employer will not be in
violation of AWPA if it fails to obtain insurance sufficient to
cover its potential liability as long as the employer maintains
insurance under state workers' compensation law. But the
possibility of underinsurance is also present where an employer is
not enrolled in a workers' compensation plan. AWPA limits the
insurance that agricultural employers must carry, 29 U.S.C. §
1841(b)(3) (1982 ed.); if a claim exceeds the required coverage, an
employer is nonetheless liable for the whole claim. §
1854(c)(1) (authorizing damages "up to and including an amount
equal to the amount of actual damages");
see also 128
Cong.Rec. 32463 (1982) ("[F]ull actual damages [are to] be awarded
in every case"). In this respect, AWPA does not differ from other
mandatory insurance regimes that require a minimum level of
coverage without establishing an absolute limit on liability. Thus,
Congress' decisions to allow workers' compensation insurance to
satisfy § 1841(b)'s minimum coverage requirements on the one
hand, and to afford migrant workers federal and state remedies that
may exceed such coverage on the other, are not incompatible;
indeed, the decisions are consistent with AWPA's treatment of
agricultural employers who are not exempted from § 1841(b)'s
insurance and bond requirements. [
Footnote 3]
Page 494 U. S. 646
We likewise reject petitioner's contention that, where Congress
authorizes a private right of action to vindicate a federal right,
we should assume that Congress has conditioned that right on the
unavailability of a state remedy. Indeed, we have stated that "it
is to be assumed when Congress enacts a statute that it does not
intend to make its application dependent on state law."
NLRB v.
Natural Gas Utility District of Hawkins County, 402 U.
S. 600,
402 U. S. 603
(1971) (internal quotation marks and citation omitted). Congress
may choose to establish state remedies as adequate alternatives to
federal relief, but federal rights should be regarded as
supplementing state-created rights unless otherwise indicated.
See, e.g., Gomez v. Toledo, 446 U.
S. 635,
446 U. S. 639
(1980) (construing 42 U.S.C. § 1983);
Tennessee C., I.
& R. Co. v. Muscoda Local No. 123, 321 U.
S. 590,
321 U. S. 597
(1944) (construing Fair Labor Standards Act).
Cases in which this Court has harmonized federal statutes that
provide overlapping federal remedies,
see, e.g., United States
v. Demko, 385 U. S. 149
(1966), are not to the contrary. In
Demko, this Court held
that the existence of a comprehensive federal scheme for
compensating injured prisoners precluded supplemental recovery
under the Federal Tort Claims Act. A finding that a specific
federal remedy trumps a more general federal remedy may be
appropriate in certain circumstances, but that conclusion is a far
cry from a presumption that a general state remedy invariably
trumps a specific federal one.
Accordingly, the plain meaning of the statute's language
indicates that AWPA's private right of action is unaffected
Page 494 U. S. 647
by the availability of remedies under state workers'
compensation law.
B
Adams Fruit also contends that Congress did not intend to
preempt States from establishing their workers' compensation
schemes as the exclusive mechanism to redress injuries to migrant
workers. In support of this position, Adams Fruit points to 29
U.S.C. § 1871 (1982 ed.), which provides that the statute
"is intended to supplement State law, and compliance with this
chapter shall not excuse any person from compliance with
appropriate State law and regulation."
On the basis of this provision, Adams Fruit argues that this
Court must give effect to the exclusivity provision in Florida's
statute, which it construes as withdrawing AWPA's private right of
action.
We disagree that Florida's exclusivity provision is intended to
preclude federal remedies. Neither the Florida Legislature nor the
Florida courts have declared such a purpose; indeed, to the limited
extent that the Florida Supreme Court has expressed a view
regarding the extraterritorial scope of the exclusivity provision,
it has stated the opposite.
See Byrd v. Richardson-Greenshields
Securities, Inc., 552 So. 2d
1099, 1102 (1989) (refusing to frustrate federal and state
sexual harassment policies through "blind adherence to the
exclusivity rule of the workers' compensation statute alone" and
expressing its commitment "not [to] apply the exclusivity rule in a
manner that effectively abrogates the policies of other law"). We
therefore decline petitioner's invitation to construe Florida law
so as to create a conflict between federal and state legislation.
[
Footnote 4]
Page 494 U. S. 648
Even if Florida's provision were directed at federal law, §
1871 does not mandate displacement of the federal remedy. Although
that section permits States to supplement AWPA's remedial scheme,
it cannot be viewed as authorizing States to replace or supersede
its remedies. Nor are we persuaded by petitioner's claim that
Congress intended to preserve the particular balance state workers'
compensation statutes generally strike between assurance of
compensation, on the one hand, and limited and exclusive liability
for the employer, on the other. Whatever the merits of this
characterization of the purposes of workers' compensation, the
point is off-target. That congressional authorization of a federal
remedy may affect the balance struck in state regulatory schemes
does not suggest that Congress intended its remedial provisions to
be effective only in certain States. Federal legislation applies in
all States, and in cases of conflict between federal law and the
policies purportedly underlying some state regulatory schemes, the
scope of federal law is not curtailed.
More generally, we refuse to adopt Adams Fruit's "reverse"
preemption principle that would authorize States to withdraw
federal remedies by establishing state remedies as exclusive. Such
provisions cannot be viewed as permissible interstitial regulation
in the service of, or at least neutral with respect to, the
purposes of the federal scheme.
Cf. Mackey v. Lanier
Collections Agency & Service, Inc., 486 U.
S. 825,
486 U. S.
834-838 (1988) (where federal law does not establish an
enforcement mechanism for collecting ERISA judgments, state
mechanisms not preempted);
Robertson v. Wegmann,
436 U. S. 584,
436 U. S. 594
(1978) (application of state survivorship rule to 42 U.S.C. §
1983 is not preempted because rule does not impair federally
secured right). Rather they directly conflict with the purposes of
the federal statute.
Page 494 U. S. 649
Accordingly, we find that AWPA preempts state law to the limited
extent that it does not permit States to supplant, rather than to
supplement, AWPA's remedial scheme.
C
Adams Fruit argues that, in the absence of any explicit
congressional statement regarding the preemptive scope of AWPA,
this Court should defer to the Department of Labor's position
that
"[w]here a State workers' compensation law is applicable and
coverage is provided for a migrant or seasonal agricultural worker
by the employer, the workers' compensation benefits are the
exclusive remedy for loss under this Act in the case of bodily
injury or death."
29 CFR § 500.122(b) (1989).
As an initial matter, we reject petitioner's view that AWPA's
failure to speak directly to the preemption of state exclusivity
provisions creates a statutory "gap" within the meaning of
Chevron U.S.A. Inc. v.
Natural Resources Defense Council, Inc.,
467 U. S. 837,
467 U. S. 843
(1984), that Congress intended the Department of Labor to fill. A
"gap" is not created in a statutory scheme merely because a statute
does not restate the truism that States may not preempt federal
law.
Moreover, even if AWPA's language establishing a private right
of action is ambiguous, we need not defer to the Secretary of
Labor's view of the scope of § 1854, because Congress has
expressly established the Judiciary, and not the Department of
Labor, as the adjudicator of private rights of action arising under
the statute. A precondition to deference under
Chevron is
a congressional delegation of administrative authority.
Bowen
v. Georgetown University Hospital, 488 U.
S. 204,
488 U. S. 208
(1988).
See also NLRB v. Food and Commercial Workers,
484 U. S. 112,
484 U. S. 123
(1987) (
Chevron review of agency interpretations of
statutes applies only to regulations "promulgated pursuant to
congressional authority");
Crandon v. United States,
494 U. S. 152,
494 U. S. 177
(1990) (SCALIA, J., concurring in judgment) (rejecting
Chevron deference
Page 494 U. S. 650
where the statute "is not administered by any agency, but by the
courts");
cf. Bureau of Alcohol, Tobacco and Firearms v.
FLRA, 464 U. S. 89,
464 U. S. 97
(1983) (refusing to sanction "
unauthorized assumption by an
agency of major policy decisions'" (quoting American Ship
Building Co. v. NLRB, 380 U. S. 300,
380 U. S. No
such delegation regarding AWPA's enforcement provisions is evident
in the statute. Rather, Congress established an enforcement scheme
independent of the Executive and provided aggrieved farmworkers
with direct recourse to federal court where their rights under the
statute are violated. Under such circumstances, it would be
inappropriate to consult executive interpretations of § 1854
to resolve ambiguities surrounding the scope of AWPA's judicially
enforceable remedy.
Congress clearly envisioned, indeed expressly mandated, a role
for the Department of Labor in administering the statute by
requiring the Secretary to promulgate standards implementing AWPA's
motor vehicle provisions. § 1841(d). This delegation, however,
does not empower the Secretary to regulate the scope of the
judicial power vested by the statute. Although agency
determinations within the scope of delegated authority are entitled
to deference, it is fundamental "that an agency may not bootstrap
itself into an area in which it has no jurisdiction."
Federal
Maritime Comm'n v. Seatrain Lines, Inc., 411 U.
S. 726,
411 U. S. 745
(1973);
SEC v. Sloan, 436 U. S. 103,
436 U. S. 119
(1978) (same);
cf. Adamo Wrecking Co. v. United States,
434 U. S. 275,
434 U. S. 288,
n. 5 (1978) (rejecting "Administrator's unexplained exercise of
supposed authority"). Accordingly, the Secretary's conclusion that
workers' compensation benefits, where available, provide the
exclusive remedy for violations of AWPA is not entitled to
Chevron deference.
III
Our review of the language and structure of AWPA leads us to
conclude that AWPA does not establish workers' compensation
benefits as an exclusive remedy under § 1854, even
Page 494 U. S. 651
where state workers' compensation schemes purport to establish
their benefits as exclusive of all other relief. [
Footnote 5] Accordingly, the decision of the
Court of Appeals is affirmed.
It is so ordered.
[
Footnote 1]
Section 1854(a) provides:
"Any person aggrieved by a violation of this chapter or any
regulation under this chapter by a farm labor contractor,
agricultural employer, agricultural association, or other person
may file suit in any district court of the United States having
jurisdiction of the parties, without respect to the amount in
controversy and without regard to the citizenship of the parties
and without regard to exhaustion of any alternative administrative
remedies provided herein."
Section 1854(c)(1) provides:
"If the court finds that the respondent has intentionally
violated any provision of this chapter or any regulation under this
chapter, it may award damages up to and including an amount equal
to the amount of actual damages, or statutory damages of up to $500
per plaintiff per violation, or other equitable relief. . . ."
[
Footnote 2]
In other statutes, Congress has expressed clearly its intent to
limit the availability of a federal remedy where a claimant has
received workers' compensation benefits related to the same injury.
See, e.g., 56 Stat. 1032, 42 U.S.C. § 1705(a) (1982
ed.) (providing that "[n]o benefits shall be paid or furnished
under [the War Hazards Compensation Act] for injury or death to any
person who recovers or receives workmen's compensation benefits for
the same injury or death under . . . the law of any State").
[
Footnote 3]
For similar reasons, we reject Adams Fruit's claim that the
refusal to exempt employers from AWPA liability where they have
obtained workers' compensation coverage upsets employers'
reasonable expectations regarding liability. Because the insurance
requirements of § 1841 establish a floor of coverage, rather
than a ceiling of liability, employers' expectations to the
contrary are unreasonable. Moreover, to the extent that Adams
Fruit's argument rests on equitable considerations, no inequity
occurs where, as here, a predicate for liability is an intentional
violation of the law.
See 29 U.S.C. § 1854(c)(1)
(1982 ed.).
[
Footnote 4]
The States of California and Texas and the Commonwealth of
Massachusetts -- appearing as
amici curiae for respondents
-- have urged this Court to affirm the decision below. Each
"has a provision in its state workers' compensation statute
making workers' recovery for personal injuries under the state
workers' insurance system the exclusive mechanism for personal
injury compensation,"
and each declares an interest in
"prevent[ing] its principal statutory mechanism for the
recompense of injured migrant workers from being transmuted into a
contraption destroying federal protection for those same
workers."
Brief for Texas
et al. as
Amici Curiae
1-2.
[
Footnote 5]
We agree with the court below that an award of actual damages
under AWPA may be offset in light of a farmworker's receipt of
benefits under state workers' compensation law.