Bayside Enterprises, Inc. v. National Labor Relations Board

Background

Bayside is three affiliated companies running a vertically integrated poultry business in Maine. Six of Bayside’s truck drivers delivered poultry feed from the company’s feedmill to 119 independently owned farms where Bayside’s chicks were raised. Bayside refused to bargain with the drivers’ union, arguing the drivers were farm workers and therefore not covered by the National Labor Relations Act. The National Labor Relations Board and the First Circuit sided with the union, and the Supreme Court agreed to decide the legal question.

Reasoning

The Court examined the statutory definition that treats some activities as primary farming and others as related work performed “by a farmer.” The Court found that hauling feed from the feedmill is not primary farming and that the feedmill and processing plant are nonagricultural operations. Because the farms were operated by independent contractors and the drivers worked for the feedmill employer, the Board reasonably concluded the drivers’ work was not performed “by a farmer.” The Court gave weight to the Board’s long-standing interpretation and upheld its order finding the drivers are not agricultural laborers.

Real world impact

The drivers are covered by the National Labor Relations Act and the company must bargain with their union. The decision limits efforts to classify delivery workers as farm laborers when they are employed by nonfarm facilities and affirms the Labor Board’s authority to decide similar mixed arrangements.