Written by: Amie Alexander, JD/MPS Candidate, William H. Bowen School of Law


Current and former employees filed a class-action lawsuit in the District Court for the Northern District of Oklahoma on October 10, 2017 against Simmons Foods, Inc. (“Simmons”) and C.A.A.I.R. Plaintiffs alleged violations of labor laws, several contracts claims, and that defendants’ conditions constituted involuntary servitude and a violation of the Thirteenth Amendment. You can access the complaint in its entirety here.

Plaintiffs in this case are current or former employees of Simmons and housed in C.A.A.I.R.’s dormitories. According to the complaint, plaintiffs were led to believe that C.A.A.I.R. was a drug and alcohol program offered through the Oklahoma court system. Plaintiffs agreed to enter into the program as a condition of probation instead of serving time in prison. C.A.A.I.R. was a work program in which participants provided chicken processing labor for Simmons without pay. Plaintiffs alleged that if participants did not complete the one-year work program, they would be sent to prison. The primary benefit C.A.A.I.R. advertises is a drug and alcohol recovery program, though it does not employ any licensed drug and alcohol counselors. Additionally, it advertises to provide room and board for program participants, which consisted of bologna sandwiches and communal bunk-bed housing.

Plaintiffs first alleged a violation of the Fair Labor Standards Act and the Oklahoma Protection of Labor Act in that Simmons failed to pay minimum wage and overtime. Plaintiffs next claimed defendants’ actions constituted a breach of contract and fraud as defendants failed to compensate workers and provide addiction services as agreed upon. Plaintiffs asserted that the working conditions at Simmons violated Human Trafficking Statutes and the Thirteenth Amendment outlawing involuntary servitude. Finally, Plaintiffs alleged that defendants were unjustly enriched from the Plaintiffs’ labor.

Plaintiffs asked the court for economic, compensatory, and punitive damages including unpaid wages, statutory penalties, costs and attorneys’ fees, and injunctive relief.