The Third Circuit Court of Appeals has refused to reconsider whether the U.S. Department of Labor (DOL) had the authority to levy more than $580,000 in penalties against Sun Valley Orchards LLC, a New Jersey-based farm accused of violating H-2A visa program regulations.

In a Wednesday order, the court denied the DOL’s bid for an en banc rehearing, leaving intact a July panel ruling that sided with the farm’s argument that it was entitled to have its case reviewed in federal court rather than through the DOL’s in-house administrative process.

The court gave no explanation for its denial, signaling a quiet but significant setback for the agency’s push to maintain control over enforcement proceedings within its own administrative framework.

The Farm’s Fight Over Fair Process

The dispute stems from a 2021 lawsuit filed by Sun Valley Orchards, which accused the DOL of blocking its right to a fair trial after the agency imposed over half a million dollars in fines for alleged H-2A visa program violations.

The H-2A program allows farms to hire temporary foreign agricultural workers, but the DOL claimed Sun Valley failed to meet federal labor standards tied to that program.

A Third Circuit panel in July found merit in the farm’s argument, holding that it could challenge the DOL’s administrative process in court — a ruling that effectively limited the department’s reach over internal enforcement.

DOL’s Argument Falls Flat

In its September petition for rehearing, the DOL argued that its actions against Sun Valley didn’t concern “private rights” and therefore didn’t need judicial oversight. But the full court declined to take the matter up, leaving the panel’s decision in place.

The rejection marks a major procedural loss for the Labor Department, potentially reshaping how H-2A enforcement actions are handled moving forward — and reaffirming that even federal agencies aren’t beyond judicial scrutiny when accused of overreach.