Frank Diehl Farms v. Secretary of Labor
United States Court of Appeals for the Eleventh Circuit
696 F.2d 1325 (11th Cir. 1983)
Frank Diehl Farms and other Florida farmers (defendants) provided free or low-cost temporary housing to seasonal migrant workers who were not required to live there and were free to work for other employers, though residents had to work at the farm when work was available. After OSHA inspected and found housing-standard violations, the Occupational Safety and Health Review Commission ruled the housing fell within the Act's jurisdiction because it was directly related to employment. The farmers appealed, arguing the housing fell outside OSHA's jurisdiction because it was never a condition of employment.
Whether the Occupational Safety and Health Act applies to worker housing that is work-related but is not itself a condition of employment.