Solis v. Laurelbrook Sanitarium and School, Inc.
642 F.3d 518
| 6th Cir. | 2011Background
- Laurelbrook is a Tennessee non-profit boarding school founded in 1950 that operates a forty-bed Sanitarium used for student vocational training.
- Laurelbrook's curriculum blends classroom instruction with practical training; students live on site and are taught in both academic and hands-on settings.
- The Sanitarium provides nursing-related care to patients and is funded in part by Medicaid; students assist in its kitchen and housekeeping departments as part of training.
- Students do not receive wages, are not guaranteed employment after graduation, and the primary purpose of student labor is educational/training rather than remuneration for work.
- The district court held that Laurelbrook’s students were not employees under the FLSA and denied injunctive relief to Secretary Solis to stop future child-labor violations.
- The Sixth Circuit affirmed, adopting a primary-benefit test for determining employment status in training contexts and focusing on which party primarily benefits from the students’ work.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What test governs employment status in training contexts? | Solis argues WHD six-factor test controls and that trainees are employees. | Laurelbrook argues no single label should decide; primary-benefit framework is appropriate and not a blanket non-employment rule. | Primary-benefit framework is proper; WHD test is not controlling. |
| Did the district court properly apply the primary-benefit test to Laurelbrook? | Solis contends the school benefits from trainee labor and thus students are employees. | Laurelbrook contends students primarily benefit educationally and the district court’s findings support non-employment. | District court properly concluded students are not employees. |
Key Cases Cited
- Walling v. Portland Terminal Co., 330 U.S. 148 (1947) (not all trainees are employees; focus on economic reality and primary benefit)
- Alamo Foundation v. Solis, 471 U.S. 290 (1985) (economic reality governs employee status; dependence as key factor)
- Donovan v. Brandel, 736 F.2d 1114 (6th Cir. 1984) (case cited for case-by-case, totality-of-the-circumstances approach)
- Fegley v. Higgins, 19 F.3d 1126 (6th Cir. 1994) (employment status is a question of law to be reviewed de novo)
- Baptist Hosp. v. Solis, 668 F.2d 229 (6th Cir. 1981) (educational value and primary-benefit considerations in training programs)
- 3Re.com, Inc. v. Solis, 317 F.3d 534 (6th Cir. 2003) (basis for reviewing district court’s legal standard and application)