Friday, November 29, 2013

Vasquez v. Glassboro Service Association, Inc. case brief

Vasquez v. Glassboro Service Association, Inc. case brief summary
415 A.2d 1156 (N.J. 1980)

Defendant farm labor service sought review of a decision from the Superior Court, Appellate Division (New Jersey), granting plaintiff migrant farm worker's petition for equitable relief by permitting plaintiff to reenter living quarters provided by defendant and by enjoining defendant from ejecting plaintiff from those living quarters except by judicial process.

Defendant farm labor service challenged the trial court's decision in favor of plaintiff migrant farm worker in an equitable action seeking to enjoin defendant from ejecting plaintiff from communal housing that defendant provided for its farm laborers. Plaintiff and other Puerto Ricans signed a contract with defendant, agreeing to harvest crops for six months in exchange for free living quarters and wages. The contract did not provide for transportation back to Puerto Rico unless plaintiff fulfilled the contract. After plaintiff was fired for poor job performance, defendant immediately ejected plaintiff from the barracks.


  • On appeal, the state's highest court held that plaintiff was not a tenant; therefore, state law ejectment procedures were inapplicable. 
  • However, the court found that the parties' bargaining power was inherently unequal; thus, their agreement was a contract of adhesion and unenforceable as against public policy. 
  • The court devised an equitable remedy, ordering that disputes concerning the dispossession of migrant farm workers upon job termination be addressed in summary judicial proceedings. 
  • The court modified the trial court's order and affirmed.

The court modified and affirmed the trial court's decision enjoining defendant farm labor service from ejecting plaintiff migrant farm worker from company housing without a summary judicial proceeding. The parties' labor agreement was void as against public policy and as a contract of adhesion because it provided no housing or transportation home for plaintiff upon termination for poor job performance.

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