A Jury Found Labor Trafficking on a Michigan Farm.

The Facts

Purpose Point Harvesting, LLC used the H-2A visa program, the federal system that lets employers bring in foreign workers for seasonal agricultural jobs, to recruit Guatemalans for farm work in Oceana and Newaygo Counties, Michigan. The company then contracted those workers out to third-party farms.

Five of those workers, Luis Gomez-Echeverria, Hervil Gomez-Echeverria, Darwin Joel Fuentes Perez, Artemio Coronado Esteban, and Leonel Lopez y Lopez, signed H-2A contracts with Purpose Point for the 2017, 2018, and 2019 growing seasons. Under federal H-2A rules, that contract is a legally binding document. Employers cannot charge recruitment fees as a condition of employment, and they must provide certain guarantees, including adequate housing, workers’ compensation insurance, tools and equipment, meals, transportation, and wages set at whichever is higher: minimum wage or the prevailing local wage, which can include piece-rate pay (payment by the bushel picked).

What the Jury Heard

According to the trial record, Purpose Point charged each plaintiff an illegal recruitment fee of $2,500 every year they worked, a sum the opinion notes amounted to over a year’s wages in Guatemala. To cover it, plaintiffs borrowed money and took out high-interest loans, sometimes paying Purpose Point back over the course of their employment. Charging H-2A workers recruitment fees as a condition of employment is prohibited outright under federal regulation, 20 C.F.R. § 655.135(j).

Plaintiffs also testified to working days that ran from 3 a.m. to as late as 10 p.m., roughly nineteen hours, without paychecks that reflected those hours. Purpose Point destroyed records tracking daily hours and piece-rate production for the 2017 and 2018 harvest seasons, which the opinion notes made it harder for plaintiffs to challenge their pay after the fact.

Housing fell short of what the contracts promised, too. Plaintiffs described living in small trailers, sometimes sleeping on couches rather than beds. They were required to buy their own rain jackets, boots, and headlamps, gear the H-2A contract was supposed to provide, and to buy food from a store owned by Lucille Jean Gomez’s father.

Confiscated Documents and Controlled Bank Accounts

Federal law makes it a crime to confiscate an H-2A worker’s identification documents. 18 U.S.C. § 1597. According to the trial record, Purpose Point regularly took plaintiffs’ passports and the Social Security cards issued to them under the H-2A program.

When plaintiffs opened accounts at a local bank, Lucille Jean Gomez added herself as an authorized user on those accounts without the workers’ knowledge. She later withdrew $2,500 from Luis Gomez-Echeverria’s account without his authorization, describing it as payment toward the recruitment fee.

Milton Moreno Gomez restricted plaintiffs’ cellphone use, limited who could visit them, and accompanied them whenever they went shopping. He told plaintiffs to keep quiet about their treatment, including to Department of Labor officials and medical staff, and threatened, according to the trial record, to have them deported, “stain” their visas, or “black-list” them from returning to the United States.

That second quotation matters. Milton Moreno Gomez’s account, that the fees never happened and the passports were held for safekeeping, was put before the jury. The jury heard both sides and found defendants liable on nearly every claim anyway. A civil verdict does not require proof beyond a reasonable doubt, the standard in a criminal case; it requires a preponderance of the evidence, meaning the jury found it more likely than not that defendants did what plaintiffs said.

A Thumb Injury and Two Weeks Without Care

Hervil Gomez-Echeverria hurt his thumb while picking asparagus. He did not receive adequate medical care for two weeks. By then, the wound had become infected, and he needed surgery.

The jury heard evidence of plaintiffs’ squalid living conditions and defendants’ refusal to provide adequate medical care, which evinced reckless disregard of the health or safety of plaintiffs.

That framing, “reckless disregard,” is not incidental. It is one of the specific factors the Supreme Court has said courts must weigh when deciding whether a punitive damages award is constitutional. The Sixth Circuit’s opinion leans on it directly.

What the Court Actually Decided: The Punitive Damages Fight

Defendants did not ask the Sixth Circuit to overturn the jury’s liability findings. They argued instead that $450,000 in punitive damages violated their due process rights under the Fifth Amendment, which the Supreme Court has said bars “grossly excessive or arbitrary punishments.” Courts evaluate that question using three factors from BMW of North America v. Gore: how reprehensible the conduct was, how the punitive award compares to the compensatory award, and whether the defendant had fair notice that this kind of conduct could carry penalties of this size.

On reprehensibility, defendants pointed out that the jury awarded only economic damages, no separate award for emotional or psychological harm, and argued that meant the jury found no reprehensible conduct at all. The Sixth Circuit rejected that reasoning. The court noted that a trafficking claim under the TVPRA already requires the jury to have found that defendants knowingly benefited from labor obtained through force, threats, or a scheme meant to make workers believe they would suffer harm if they didn’t comply. That finding alone, the court held, carries built-in reprehensibility. Add the confiscated passports, the destroyed records, the illegal fees, and the delayed medical care, and the court found ample evidence to support the award.

On the ratio between punitive and compensatory damages: the total award works out to roughly 1:4.3, and each individual plaintiff’s ratio falls in the single digits, except Hervil’s, which the court calculated at about 1:9.5 given the severity of his untreated injury and his need to flee. The Supreme Court has said single-digit multipliers are more likely to satisfy due process, and the Sixth Circuit has previously upheld far higher ratios in other cases, including one at roughly 1:42.5 and another at roughly 1:50.

On fair notice: the court compared the punitive award to what defendants could have faced under existing law. Labor Department regulations allow civil penalties up to $7,289 per willful H-2A violation and $2,166 per non-willful violation, and a TVPRA violation carries potential criminal penalties of up to 20 years in prison plus fines of $250,000 for individuals and $500,000 for organizations. The jury’s award, the court noted, came in well under what the law already authorizes for conduct like this.

The Other Appeals: Mistrial, Missing Witnesses, and Guatemala

Defendants also lost on every procedural argument they raised.

During trial, plaintiffs’ counsel asked Luis Gomez-Echeverria, in front of the jury, why he seemed distressed. He answered that his ex-partner was in the courtroom and that he believed defendants had brought her there to pressure him. Defendants moved for a mistrial. The district court struck the testimony, instructed the jury to disregard it, and let the trial continue. The Sixth Circuit found no abuse of discretion: the exchange spanned only about ten questions out of an eight-day trial, and courts presume juries follow curative instructions unless there’s an “overwhelming probability” otherwise.

Defendants also wanted to call roughly 80 other H-2A workers who had worked for Purpose Point but never interacted with these five plaintiffs. The trial court allowed five who had worked alongside plaintiffs and excluded the rest, reasoning that workers with no personal knowledge of how these specific plaintiffs were treated had nothing relevant to add and risked confusing the jury. The Sixth Circuit agreed.

On the statute of limitations, defendants argued several claims were filed too late. That argument mostly collapsed on inspection: some of the plaintiffs defendants named never actually brought the claims in question, and defendants had waived their limitations defense to one claim by failing to raise it in their first response to the lawsuit, a requirement under Michigan law.

Finally, defendants asked the district court to dismiss the case entirely and send it to Guatemala under the doctrine of forum non conveniens, which lets a court decline a case that would be more appropriately tried elsewhere. To win that argument, defendants had to show Guatemala offered an adequate alternative forum. Their supporting evidence amounted to a general assertion that Guatemalan law provides remedies for breach of contract, wage violations, and trafficking, without citations to Guatemalan law, treatises, or expert testimony. The Sixth Circuit called that insufficient and noted that the underlying conduct, including the exploitation, coercion, and threats, all occurred in Michigan.

What a Legitimate Fix Looks Like

The following recommendations are the publication’s own analysis, grounded in the failure modes documented in the trial record and the Sixth Circuit’s opinion. They are not findings of the court, the jury, or any government agency.

What to Watch

What Remains Unresolved

The liability question is closed. A jury heard both sides, including Milton Moreno Gomez’s denials, and found defendants liable on nearly every claim. The Sixth Circuit reviewed that verdict and the damages attached to it and found no constitutional or procedural problem with any of it.

What the opinion does not resolve is what happens next for the five men at the center of it. The court’s ruling confirms what they are owed. It says nothing about whether Purpose Point Harvesting, LLC and its owners have the assets, or the willingness, to actually pay it. That is the part of this case that ends where the opinion does: affirmed, but not yet collected.

The source document for this investigation is attached below.