Destroyed pay records and $2,500 fees helped seal a verdict the owners couldn't shake
A federal appeals court upheld a $450,000 punitive award against a Michigan farm contractor found liable for forcing and underpaying Guatemalan guest workers.
The US Court of Appeals for the Sixth Circuit affirmed the verdict on August 28, 2026, rejecting every argument raised by Purpose Point Harvesting and its two owners.
Purpose Point recruited five Guatemalan citizens for seasonal farm work in West Michigan through the H-2A visa program, which lets employers hire foreign nationals for temporary agricultural jobs. The workers picked crops from 2017 to 2019. The Department of Labor tightly regulates the program and bars employers from charging recruitment fees.
According to the opinion, the owners charged each worker a $2,500 recruitment fee every year - more than a year's wages in Guatemala. Workers put in days running from 3 a.m. to as late as 10 p.m., but their paychecks never showed the hours. The owners destroyed the records tracking daily hours and piece-rate pay for the 2017 and 2018 seasons.
Workers lived in small trailers, often sleeping on couches. They bought their own boots, rain jackets and headlamps. One worker who injured his thumb picking asparagus waited two weeks for care; the wound became infected and needed surgery. The owners confiscated passports and Social Security cards, which federal law forbids. One owner made herself an authorized user on the workers' bank accounts and pulled $2,500 from one account without permission. When workers spoke of leaving, the opinion said, a threat followed to "stain" their visas or "black-list" them from returning.
A jury found the owners liable under the Trafficking Victims Protection Reauthorization Act, the Fair Labor Standards Act and Michigan law. It awarded $105,000 in compensatory damages and $450,000 in punitive damages, plus $803,352.50 in attorneys' fees and $101,281.20 in costs.
On appeal, the owners argued the punitive award was unconstitutionally high, partly because the jury gave no damages for emotional harm. The court disagreed. It said forced-labor conduct is inherently serious, the workers were financially vulnerable, and the 1:4.3 ratio between compensatory and punitive damages sat well within limits.
The court also upheld the exclusion of 80 defense witnesses who never worked alongside the plaintiffs and knew nothing about their treatment. And it refused to move the case to Guatemala.
For HR teams that use labor contractors or guest workers, the owners' total bill - damages, fees and costs - topped $1.4 million on a $105,000 compensatory verdict.
