Billy Schumann v. Collier Anesthesia, P.A.
803 F.3d 1199
| 11th Cir. | 2015Background
- Twenty-five former student registered nurse anesthetists (SRNAs) sued Wolford College and affiliated anesthesia practice (Collier) under the FLSA seeking unpaid wages/overtime for clinical training hours required for a CRNA master’s degree and licensure.
- Wolford’s accredited program required extensive clinical participation (minimum 550 cases) over four semesters; clinical sites often involved Collier personnel and students wore Wolford insignia while being supervised and evaluated daily.
- Defendants presented evidence students were informed they were not employees, received academic credit/assessments, were paid a clinical fee by Collier to Wolford, and that supervising CRNAs/anesthesiologists incurred training burdens; defendants argued students did not displace paid staff.
- Plaintiffs produced testimony (scheduling coordinator) and evidence that SRNAs sometimes worked >40 hours/week, were scheduled year‑round, and allegedly displaced CRNA hours—plus use of a Medicare “CRNA Teaching Rule” permitting billing for one CRNA supervising two students.
- District court granted summary judgment for defendants, finding SRNAs were not FLSA “employees.” Plaintiffs appealed; Eleventh Circuit reviews de novo and vacated/remanded to apply a tailored primary‑beneficiary test for modern internships.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether SRNAs are "employees" under the FLSA | SRNAs performed work that benefited Collier (displacing CRNAs, long hours) and thus were employees entitled to wages/overtime | SRNAs were trainees in an educational program, identified as students, not entitled to compensation; supervision and evaluations show educational focus | Remanded: court adopts a modernized “primary beneficiary” test (based on Glatt) and directs district court to apply factors to determine employment status |
| Proper standard to apply (DOL six‑factor test vs. Portland Terminal/Glatt) | Defer to DOL Field Operations Handbook six‑factor test | Portland Terminal primary‑beneficiary framework controls; DOL guidance is not persuasive | Court rejects DOL test wholesale, adopts flexible Glatt factors tailored to modern internships |
| Impact of Medicare CRNA Teaching Rule (billing for one CRNA supervising two students) on employee status | Teaching Rule shows Collier economically benefited and displaced CRNAs, supporting employee status | Medicare rule alone does not prove displacement or unfair advantage; scheduling is complex and students often burden supervisors | Teaching Rule is relevant factual context but does not alone determine primary beneficiary; district court should weigh it under factor analysis |
| Whether summary judgment was appropriate on the record presented | Plaintiff: genuine disputes of material fact (hours, displacement, scheduling, benefits) preclude summary judgment | Defendant: uncontroverted evidence students were primarily beneficiaries and not employees | Vacated summary judgment; factual issues should be evaluated under the Glatt factors on remand (district court may permit further record development) |
Key Cases Cited
- Portland Terminal Co. v. United States, 330 U.S. 148 (Sup. Ct. 1947) (establishes trainee/employee analysis and warns FLSA should not convert students into employees when training primarily benefits trainees)
- Glatt v. Fox Searchlight Pictures, Inc., 791 F.3d 376 (2d Cir. 2015) (adopts seven‑factor primary‑beneficiary test for modern internships)
- Scantland v. Jeffry Knight, Inc., 721 F.3d 1308 (11th Cir. 2013) (standard of review and discussion of FLSA definitions)
- Donovan v. Am. Airlines, Inc., 686 F.2d 267 (5th Cir. 1982) (endorses a balancing analysis for trainee status)
- Solis v. Laurelbrook Sanitarium & Sch., Inc., 642 F.3d 518 (6th Cir. 2011) (examines benefits to trainees versus employer in internship context)
- Rutherford Food Corp. v. McComb, 331 U.S. 722 (Sup. Ct. 1947) (FLSA’s broad scope to protect low‑paid workers)