In the case of Adams Fruit Co., Inc. v. Barrett et al., 1989, the U.S Supreme Court was tasked with determining whether a state law providing remedies for agricultural workers injured in their employment could be applied to those covered by federal laws under the Migrant and Seasonal Agricultural Worker Protection Act (AWPA). The Florida District Court of Appeal had ruled that such state-provided remedies were not precluded by AWPA, but this decision was reversed by the Supreme Court. The court held that Congress intended for AWPA to provide comprehensive protection for migrant and seasonal agricultural workers, including access to federal courts for enforcement actions. Therefore, it preempted any conflicting or supplementary state legislation on these matters.

In the dissenting opinion for ADAMS FRUIT CO., INC. v. BARRETT et al., Justice Scalia argued that the majority misinterpreted Congress's intent in passing the Migrant and Seasonal Agricultural Worker Protection Act (AWPA). He contended that while AWPA does provide a private right of action to migrant workers, it doesn't necessarily preempt state law remedies unless they are incompatible with federal law. In this case, he believed Florida’s workers' compensation scheme was not incompatible with AWPA because both could coexist without conflict; thus, there was no need for preemption. Furthermore, he criticized the majority's reliance on legislative history instead of clear statutory text to determine congressional intent and warned against judicial overreach into policy-making territory reserved for Congress.