Migrant workers at a Florida farm were required to pay expenses out of pocket for securing work visas and traveling to job sites. Because these costs amounted to "pre-employment deductions" from wages, the 11th Circuit Court of Appeals said the company violated the Fair Labor Standards Act by failing to cover any costs that lowered the workers' first-week pay below minimum wage. (Arriaga v. Florida Pacific Farms LLC, No. 01-16402, 11th Cir., 2002)
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