Sun Valley Orchards is a New Jersey farm that employed nonimmigrant foreign seasonal workers under the H-2A visa program. The H-2A visa program requires participating employers to, inter alia, post a job order detailing the workers' rights to pay, facilities, and other benefits. The job order, in the absence of any other written agreement with the workers, operates as a contract that the DOL can enforce against the employer. The DOL investigated Sun Valley Orchards and cited it for a host of violations of H-2A rules incorporated into the job order concerning housing, transportation, meals, and wages provided to its workers. The agency assessed more than $200,000 in civil penalties and more than $300,000 in back wages. Following DOL regulations, Sun Valley Orchards challenged the agency's determination before a DOL ALJ, who largely affirmed the DOL's findings.