Federal Court Invalidates New H-2A Wage Methodology, Citing APA Violations
A federal court in the Eastern District of California has invalidated the Department of Labor's (DOL) new methodology for calculating the H-2A Adverse Effect Wage Rate (AEWR). The court, in the case of United Farm Workers v. United States Department of Labor, found that the DOL's interim final rule, effective October 2, 2025, violated the Administrative Procedure Act (APA). The ruling specifically identified several components of the new methodology as arbitrary and capricious, including a two-tier wage system, a housing adjustment that reduced the AEWR, the use of Occupational Employment and Wage Statistics (OEWS) data, and a 'greater than 50 percent' rule for occupational classifications. The court determined that the DOL improperly bypassed the normal notice-and-comment process when implementing these substantive changes. While the court did not immediately vacate the rule to avoid disrupting agricultural labor markets, it remanded the matter to the DOL to develop a new, compliant methodology. This mean... 
