Solis v. Laurelbrook Sanitarium and Sch., Inc.

The government sought an injunction under the child labor provisions of the Fair Labor Standards Act of 1938, 29 U.S.C. 201-219, based on the boarding school's use of uncompensated minors in its kitchen and housekeeping departments, agricultural operations, auto repair shop, Sanitarium, and other operations. The district court concluded that the students are not employees and, therefore, not subject to the Act. The Sixth Circuit affirmed. The court rejected the school's claim that students in a vocational program can never be considered employees and the government's argument that the test of whether "trainees" are employees should apply, and applied a "primary benefit" test. The school staff is sufficient to perform the work even if the students did not work and the school is not at competitive advantage with respect to the work; the students benefit from hands-on training in an accredited program that is run consistently with their parents' religious beliefs.