Diaz v. Kay-Dix Ranch

In Diaz v. Kay-Dix Ranch (1970) 9 Cal. App. 3d 588 88 Cal. Rptr. 443 (Diaz), migratory farmworkers filed a class action suit under former Civil Code section 3369, the predecessor to the current UCL, seeking to enjoin the employment of illegal immigrants in the farming industry. (Diaz, supra, at pp. 590-591.) The trial court sustained the defendant's demurrer and the plaintiffs appealed. (Ibid.) The Diaz court framed the issue on appeal as a question of whether injunctive relief was proper ( id. at p. 592) and concluded that it was not: "Plaintiffs seek the aid of equity because the national government has breached the commitment implied by national immigration policy. It is more orderly, more effectual, less burdensome to the affected interests, that the national government redeem its commitment. Thus the court of equity withholds its aid." ( Id. at p. 599.) The Supreme Court subsequently adopted the Diaz rationale in People ex rel. Dept. of Transportation v. Naegele Outdoor Advertising Co. (1985) 38 Cal. 3d 509, 523 213 Cal. Rptr. 247, 698 P.2d 150 (Naegele), another case involving the intersection of federal and state law in the context of regulating billboards on Indian lands. (See also Congress of Cal. Seniors v. Catholic Healthcare West (2001) 87 Cal. App. 4th 491, 510-511 104 Cal. Rptr. 2d 655.)