The California Agricultural Labor Relations Act (CALRA) is a landmarkEditorial. "Farm Workers’ Rights, 70 Years Overdue." New York Times. April 5, 2009. statute in United States labor law that was enacted by the state of California in 1975,"Governor Signs Historic Farm Labor Legislation." Los Angeles Times. June 5, 1975. establishing the right to collective bargaining for farmworkers in that state, a first in U.S. history.Hurt, R. Douglas. American Agriculture: A Brief History. Lafayette, Ind.: Purdue University Press, 2002.

The goal of the Act is to "ensure peace in the agricultural fields by guaranteeing justice for all agricultural workers and stability in labor relations."Agricultural Labor Relations Act of 1975, Cal.Stats. 1975, Third Extraordinary Session, c. 1 Sec. 1 at 4013. The Act, part of the California Labor Code, explicitly encourages and protects "the right of agricultural employees to full freedom of association, self-organization, and designation of representatives of their own choosing, to negotiate the terms and conditions of their employment, and to be free from the interference, restraint, or coercion of employers of labor, or their agents, in the designation of such representatives or in self-organization or in other concerted activities for the purpose of collective bargaining or other mutual aid or protection."Agricultural Labor Relations Act. California Labor Code. Division 2, Part 3.5, Section 1140.2.

The Act established rules and authorized regulations similar to those of National Labor Relations Act, a federal law which formally protected the collective bargaining rights of most American workers except farm and domestic workers.Higgins, John E. and Janus, Peter A. The Developing Labor Law: The Board, the Courts, and the National Labor Relations Act. 5th ed. Washington, D.C.: BNA Books, 2006. The California Agricultural Labor Relations Board (ALRB) administers the Act. The ALRB has two functions: To conduct, oversee, and certify representation elections, and to investigate unfair labor practice (ULP) charges and pursue remedies. Administrative law judges and agency staff adjudicate most cases, with the five-member Board serving as a final arbiter.

Background Collective bargaining rights for most hourly workers in the United States were first given legal protection in 1933 by Section 7a of the National Industrial Recovery Act (NIRA). Although NIRA did not specifically exempt agricultural laborers from the protection of the Act, the Roosevelt administration—eager to win over farm-state members of Congress—argued that farmworkers were excluded.Weber, Devra. Dark Sweat, White Gold: California Farm Workers, Cotton, and the New Deal. Berkeley, Calif.: University of California Press, 1996. When the National Labor Relations Act (NLRA) was enacted in 1935, it, too, specifically exempted agricultural workers due to pressure from the "farm bloc" in Congress.The NLRA was not the only federal law to discriminate against farmworkers. The Social Security Act of 1935 and Fair Labor Standards Act of 1938 also excluded them. See: Hurt, American Agriculture: A Brief History, 2002. Although a number of attempts were made in the 1920s, 1930s and 1940s to organize farm laborers, these efforts were unsuccessful.Bernstein, Irving. The Lean Years: A History of the American Worker, 1920-1933. Paperback ed. Baltimore: Penguin Books, 1972. (Originally published 1960); Bernstein, Irving. The Turbulent Years: A History of the American Worker, 1933-1941. Paperback edition. Boston: Houghton-Mifflin Co., 1970. (Originally published 1969.)

In August 1966, the National Farm Workers Association and Agricultural Workers Organizing Committee, two unrecognized and relatively minor labor unions claiming to represent farm workers in California, merged to form the United Farm Workers Organizing Committee (the predecessor organization to the United Farm Workers).Feriss, Susan; Sandoval, Ricardo; and Hembree, Diana. The Fight in the Fields: Cesar Chavez and the Farmworkers Movement. New York: Houghton Mifflin Harcourt, 1998. Adopting the philosophy of pacifism in the face of often violent reaction to its organizing efforts and engaging in strikes, hunger strikes, boycotts and secondary boycotts (including the particularly successful Delano grape strike), marches, rallies, and cutting-edge public relations campaigns, the United Farm Workers (UFW) began organizing large numbers of agricultural laborers into unions. In some cases, the UFW even won recognition and negotiated contracts.

Impetus for legal action

The Salad Bowl strike

A series of violent strikes and inter-union jurisdictional battles set the political stage for passage of the California Agricultural Labor Relations Act. By 1969, the UFW was on the verge of winning the four-year-old Delano grape strike. But as the Delano grape strike seemed to be ending, an attempt by the International Brotherhood of Teamsters to organize farm laborers in the Salinas Valley in California led to the costly "Salad Bowl strike."Bernstein, Harry. "Harvest, Shipping Near Standstill in 'Salad Bowl' Strike." Los Angeles Times. August 26, 1970. Six thousand drivers and packing workers represented by the Teamsters struck on July 17, 1970, winning a contract on July 23 under which growers gave the Teamsters, not the UFW, access to farms and the right to organize workers into unions."From Fruit Bowl to Salad Bowl." Time. September 14, 1970."Strike By Teamsters Hits Produce Crops." Los Angeles Times. July 18, 1970; "Salinas Agreement Ends Lettuce Strike." Los Angeles Times. July 24, 1970; "6,000 Back in Lettuce Fields." Los Angeles Times. July 25, 1970."Chavez Union Plans Salinas Protest Walk." Los Angeles Times. July 31, 1970. Secret talks between the UFW and the Teamsters led to an agreement to return jurisdiction over the field workers to the farm union,Bernstein, Harry. "Battle Between Teamsters and Chavez Looms." Los Angeles Times. August 5, 1970; Bernstein, Harry. "Chavez Union and Teamster Talks Revealed." Los Angeles Times. August 7, 1970; Bernstein, Harry. "Teamsters Give Chavez Clear Field to Organize Farm Hands." Los Angeles Times. August 13, 1970. but the agreement collapsed on August 23 and 7,000 UFW workers struck the Salinas Valley growers."Coast Workers Vote Strike At 27 Vegetable Ranches." Associated Press. August 24, 1970; Bernstein, Harry. "Massive Farm Strike Begins." Los Angeles Times. August 25, 1970; Bernstein, Harry. "5,000-7,000 Strike in Largest Farm Walkout in U.S. History." Los Angeles Times. August 25, 1970. Violence, sporadic at first but increasingly widespread, began to occur in the fields.Roberts, Steven V. "Fear and Tension Grip Salinas Valley in Farm Workers' Strike." New York Times. September 6, 1970; "Union Office Is Bombed." New York Times. November 5, 1970. On December 4, federal marshals arrested and jailed César Chávez.Roberts, Steven V. "Chavez Is Jailed In Lettuce Strike." New York Times. December 5, 1970; "Chavez Jailed First Time, Urges Union to Press Boycott." Los Angeles Times. December 5, 1970. Two days later, an anti-union mob nearly rioted when former Olympic gold medal-winning decathlete Rafer Johnson and Ethel Kennedy, widow of slain Senator Robert F. Kennedy visited Chávez in jail. The two unions signed a new jurisdictional agreement reaffirming the UFW's right to organize field workers,Bernstein, Harry. "New Pact to End Unions' Long Lettuce Dispute Reported Near." Los Angeles Times. March 17, 1971; Turner, Wallace. "Chavez-Teamsters Pact Ends Lettuce Labor Rift." New York Times. March 27, 1971; Bernstein, Harry. "New Teamster-Chavez Peace Treaty Signed." Los Angeles Times. March 27, 1971; Kendall, John. "Chavez Signs Nation's Largest Independent Lettuce Producer." Los Angeles Times. April 24, 1971; Bernstein, Harry. "Teamsters Ask Farms to Sign Chavez Pacts." Los Angeles Times. May 12, 1971.

Worsening violence of the jurisdictional dispute The Teamsters resumed their dispute with the UFW in December 1972, which led to further extensive disruptions in the state agricultural industry, mass picketing, mass arrests, and extensive violence.Arneson, Eric, ed. Encyclopedia of U.S. Labor and Working-Class History. New York: Routledge, 2007. Bernstein, Harry. "Teamsters President Proposes Alliance With Growers Group." Los Angeles Times. December 13, 1972; Bernstein, Harry. "Teamsters to Seek New Farm Pacts; Fight With Chavez Seen." Los Angeles Times. December 14, 1972; "Teamsters End a Truce With Chavez's United Farm Workers." New York Times. December 15, 1972. Many growers signed contracts with the Teamsters on April 15, and thousands of UFW members began picketing in the fields."Teamsters Gain California Farms." New York Times. April 16, 1973; Del Olmo, Frank. "Teamsters Sign First Grape Pacts." Los Angeles Times. April 16, 1973. Mass arrests jailed more than 1,700 UFW members by late July (some county jails had three times the number of detainees they were legally capable of holding),"33 Farm Worker Pickets Arrested." Los Angeles Times. April 18, 1973; "135 More Picketers Held In Coast Vineyard Dispute." New York Times. April 20, 1973; "350 Pickets of UFWU Jailed in Kern County." Los Angeles Times. July 18, 1973; Del Olmo, Frank. "450 Arrested in Kern County Farm Dispute." Los Angeles Times. July 19, 1973; "Chavez' Pickets Defy Court Order; Kern County Jail Full." Los Angeles Times. July 21, 1973; Caldwell, Earl. "Grape Workers Assail Judges As Arrests of Pickets Continue." New York Times. July 21, 1973; "Arrest Toll Is 1,700 For Chavez Pickets." New York Times. July 22, 1973. and UFW members accused law enforcement officers of beating detainees.Del Olmo, Frank. "Chavez Seeks Inquiry Into Policing of Strike." Los Angeles Times. July 18, 1973; Del Olmo, Frank. "Inquiry Urged Into Charges of Beatings of Jailed Pickets." Los Angeles Times. July 26, 1973; Townsend, Dorothy. "FBI Asked to Probe Charges of Brutality to Grape Strikers." Los Angeles Times. July 29, 1973.

Soon organizing battles between the two unions became violent. "Flying squads" of Teamsters began attacking UFW supporters in broad daylight in the Coachella Valley.Pandol, Jack. "Violence on the Grape Farms." Los Angeles Times. July 14, 1973. The violence worsened when the dispute moved into the Delano vineyards. Seventy farm workers were attacked on July 31, a UFW picketer was shot on August 3, five firebombs were thrown at UFW picket lines on August 9, two UFW members were shot on August 11, and a UFW picketer was shot to death on August 16."70 Nonunion Farm Workers Attacked." Los Angeles Times. July 31, 1973; Del Olmo, Frank. "Arrests, Trouble Mark Second Day of Escalated Grape Strike." Los Angeles Times. August 1, 1973; Del Olmo, Frank. "Court Curbs Pickets at Major Vineyard." Los Angeles Times. August 2, 1973; Caldwell, Earl. "Picket Shot, Many More Arrested in Grape Strike." New York Times. August 3, 1973; "Firebombs Hurled in Area Of Grape Labor Disputes." New York Times. August 9, 1973; "2 Chavez Pickets Shot in Clash With Nonunion Workers." Los Angeles Times. August 11, 1973; "Shots Fired at Chavez' Son in Vineyard Fight." Los Angeles Times. August 15, 1973; "Chavez Picket Shot to Death On Coast." New York Times. August 17, 1973; Del Olmo, Frank. "Chavez Picket Shot to Death in Violence Near Bakersfield." Los Angeles Times. August 17, 1973. Finally, a tentative agreement was reached on September 27, 1973; the Teamsters again agreed to leave jurisdiction over farm field workers to the UFW.Shabecoff, Philip. "Chavez Reaches Tentative Accord." New York Times. September 28, 1973."Chavez Says Pact Means Teamsters Will Leave Fields." New York Times. September 29, 1973./