6th Circuit: Seventh Day Adventist Vocational School Students Are Not "Employees" Under FLSA

In Solis v. Laurelbrook Sanitarium and School, Inc., (6th Cir., April 28, 2011), the U.S. 6th Circuit Court of Appeals held that student trainees in a Seventh Day Adventist vocational boarding school are not employees for purposes of the federal Fair Labor Standards Act. High school students spend four hours each day, without pay, as part of their training working in the kitchen and housekeeping departments of Laurelbrook Sanitarium, an intermediate care nursing home that is an integral part of the school's facility. Students in the Certified Nursing Assistant program may be assigned to provide medical assistance to patients. Applying the "primary benefit" test, the court concluded that the district court was correct in concluding that "[a]lthough there is benefit to the school and sanitarium from the students’ activities, the totality of the circumstances shows that the primary benefit is to the students, who learn practical skills about work, responsibility, and the dignity of manual labor in a way consistent with the religious mission of their school." Courthouse News Service reports on the decision.