Farmers Bros. Coffee v. WCAB, 133 Cal. App. 4th 533, 35 Cal. Rptr. 3d 23 (2005)

When Rafael Ruiz, an illegal alien, sought workers’ compensation benefits from his employer, Farmers Brothers Coffee, the company asserted that the California law under which Ruiz could be considered an employee was preempted by the federal Immigration Reform and Control Act of 1986 (IRCA). The WCAB rejected the employer’s contentions, and the company filed a petition for writ of review with the Court of Appeal. The appellate court affirmed the WCAB, holding that there is no preemption language in IRCA expressly affecting state workers’ compensation laws. The Court further rejected Farmers Brothers’ contention that Ruiz’s use of a fraudulent Social Security card and a fraudulent green card to obtain employment disqualified him from obtaining benefits since Ruiz had never been convicted of violating the law in connection with those fraudulent documents.