Schumann v. Collier Anesthesia, No. 14-13169 (11th Cir. 2015)Annotate this Case
Plaintiffs, former student registered nurse anesthetists, filed suit under the Fair Labor Standards Act, 29 U.S.C. 201 et seq., seeking to recover unpaid wages and overtime for their clinical hours. The district court determined that plaintiffs were not “employees” of defendants and entered summary judgment for defendants. The court adopted an application of Walling v. Portland Terminal Co.'s “primary beneficiary” test specifically tailored to account for the unique qualities of the type of internship at issue in this case. The court remanded to allow the district court to apply this test in the first instance and, if the district court desires, to give the parties an opportunity to further develop the record to address the components of the test.