Wang v. The Hearst Corporation, 203 F.Supp.3d 344

Six former unpaid interns (Leszuk, Rappaport, Spencer, Wagster, Wang, Wheels) sued Hearst alleging violations of the FLSA and NYLL for not paying minimum wage.
Each intern performed magazine-related tasks (data entry, sample runs, bookings, marketing support, accessories handling, editorial assistance), received varying levels of hands-on experience, and listed internships on resumes or used supervisors as references.
Most interns understood the positions were unpaid and not promises of paid employment; Hearst typically required a school credit letter for participation.
Some interns received academic credit or had internships tied to coursework; others sought credit but did not ultimately receive it.
The Second Circuit remanded after clarifying the applicable "primary beneficiary" test in Glatt v. Fox Searchlight Pictures, and Hearst moved for summary judgment under that standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether interns are "employees" under FLSA/NYLL (primary beneficiary test)	Plaintiffs: work performed was largely menial, displaced paid employees, and lacked sufficient educational value to be unpaid internships	Hearst: internships provided hands-on educational benefits, were tied to academics/schedules, were unpaid with no expectation of hire	Court: Plaintiffs were interns, not employees; summary judgment for Hearst granted
Whether interns reasonably expected compensation or a job	Plaintiffs: sought more mentorship and substantive training; unpaid status led to exploitation	Hearst: interns knew positions were unpaid and not guaranteed jobs; proof of understanding supports intern status	Court: No dispute interns knew positions were unpaid; this factor favors Hearst
Whether internships provided training analogous to educational environment	Plaintiffs: tasks were rote and learned quickly; supervision inadequate	Hearst: interns gained practical, vocational skills and industry exposure	Court: Hands-on learning present; factor slightly favors Hearst
Whether intern work displaced paid employees	Plaintiffs: some tasks were scut work and sometimes substituted for paid roles	Hearst: work often complemented staff and provided educational benefit	Court: Evidence supports some displacement but also complementary work; factor slightly favors Plaintiffs

Glatt v. Fox Searchlight Pictures, Inc., 811 F.3d 528 (2d Cir. 2015) (articulates the "primary beneficiary" multi-factor test for internships under FLSA/NYLL)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment standard: materiality and genuine dispute definitions)
Ricci v. DeStefano, 557 U.S. 557 (U.S. 2009) (discusses appellate review and standards for assessing evidence in context of motions)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (standards for drawing inferences on summary judgment)
Brock v. Superior Care, Inc., 840 F.2d 1054 (2d Cir. 1988) (worker/employee classification as question of law)
Schumann v. Collier Anesthesia, P.A., 803 F.3d 1199 (11th Cir. 2015) (applies Glatt framework and warns against exacting formula for internship design)
Allen v. Coughlin, 64 F.3d 77 (2d Cir. 1995) (courts must view evidence in light most favorable to non-movant on summary judgment)