Vasquez v. Glassboro Service Association, Inc.

Supreme Court of New Jersey · 1980 · Property

415 A.2d 1156 (1980)

Updated July 23, 2026

Propertyself-help evictionmigrant farmworkersjudicial processpublic policycontracts of adhesionreasonable time to find housingsummary proceeding

Facts

Glassboro, a nonprofit farm labor service, recruited Puerto Rican migrant farmworkers under a standardized contract negotiated with the Puerto Rican Department of Labor and housed them in barracks at its New Jersey labor camp. The contract allowed Glassboro to terminate employment promptly and did not provide a fired worker any time to remain in the camp or any comparable return-transportation protection given to a worker who became physically unfit. After Vasquez was discharged for unsatisfactory work, Glassboro held the contractual hearing within hours and then ordered him to gather his belongings and leave that same day, even though space remained in the barracks. Vasquez spoke only Spanish, had no funds to return to Puerto Rico, and had to seek emergency shelter elsewhere.

Issue

Must a farm labor service that provides living quarters to migrant farmworkers use judicial process rather than self-help to dispossess a worker who remains after termination of employment? Also, is such a worker a tenant within N.J.S.A. 2A:18-61.1(m), and does the contract permit immediate removal without a reasonable opportunity to find shelter?

Rule

A migrant farmworker housed by a farm labor service is not a tenant within N.J.S.A. 2A:18-61.1(m), but the labor service still may not use self-help to dispossess the worker after termination of employment. Because immediate removal without a reasonable opportunity to secure shelter is contrary to New Jersey public policy, courts will imply into the contract a provision granting a reasonable time to find alternative housing and require dispossession through a judicial proceeding, ordinarily in a summary action under Rule 4:67, with equitable relief tailored to the circumstances.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Garden Plains Harvest Cooperative recruits seasonal field workers from Texas to pick vegetables in southern New Jersey. It houses them in dormitory-style barracks with shared bathrooms and no separate family units, and when one worker is fired, the cooperative argues he is a residential tenant because his housing was conditioned on his employment "in some other capacity."

If a New Jersey court follows the governing doctrine, which is the strongest conclusion about the worker's status under N.J.S.A. 2A:18-61.1(m)?

Explanation. The majority held that migrant farmworkers are not tenants within N.J.S.A. 2A:18-61.1(m). Applying ejusdem generis, the phrase "in some other capacity" is limited to employees of the same class as superintendents and janitors, not migrant field workers housed intermittently in shared barracks. Lack of rent, family occupancy, and the special camp conditions reinforced that conclusion.