Supreme Courts 1990 decision in Adams Fruit Co.. Inc. versus Barrett. In this decision. the Court held that injured farmworkers may bring a private cause of action under the Migrant and Seasonal Agricultural Worker Protection Act [MSPA]. even though the workers had already received workers compensation benefits for those same injuries. The implications of the Adams Fruit decision are quite troubling as the decision undermines the general principle of the exclusivity of workers compensation. both in the MSPA context and beyond. The workers compensation system was designed as a quid pro quo system in which employees forego the right to a tort remedy in exchange for readily accessible relief without questions of liability or contributory negligence.