Farmers Reservoir & Irrigation Co. v. McComb

Background

A mutual irrigation company in Colorado owns reservoirs and long canals that collect, store, and deliver water only to its farmer stockholders. The company hires field workers (ditch riders, lake tenders, maintenance men) who operate headgates and maintain the system, and it employs a single bookkeeper in its Denver office. The Wage and Hour Administrator sued because the company failed to follow federal wage, hour, and record-keeping rules, and the company claimed its workers were exempt as people "employed in agriculture."

Reasoning

The Court agreed the workers help produce farm products for commerce but examined the Act’s definition of "agriculture." It distinguished work that is merely necessary to farming from work that is itself farming. The Court found the irrigation company’s operations are separately organized, not done on a farm, and not performed by farmers. Congress had limited the exemption to practices done by a farmer or on a farm. The Court therefore held the ditch workers and the bookkeeper are not covered by the agricultural exemption even though their work is essential to farming.

Real world impact

The decision means federal wage-and-hour laws apply to employees of this type of mutual irrigation company. Ownership by farmers or nonprofit status does not automatically create an agricultural exemption. The judgment of the Court of Appeals was affirmed, and the case was sent back for enforcement of the Act against the company.

Dissents or concurrances

One Justice concurred without reservation. A dissent argued that the irrigation work is so integral to farming and owned by the farmers that those employees should be treated as "employed in agriculture."