## Facts

- Troy Adams, David Roulo, Wayne Carlisle, and Shawn Adams worked as batboys for the Detroit Tigers during the 1992–1995 seasons.
- They performed on-field duties during games and clubhouse duties such as distributing towels and uniforms, cleaning equipment, stocking coolers, and daily cleaning and straightening.
- During each home game, one batboy performed the visible on-field role; others stayed in the dugout answering phones or acting as runners.
- The batboys were paid a daily rate and received some in-kind benefits and tips, but alleged they were not paid required minimum wage or overtime.
- Tiger Stadium primarily hosted Tigers home games during a season running about April through October; it was closed to the public from November through March.
- The Tigers presented receipts evidence showing off-season receipts were less than one-third of in-season receipts.

## Issues

1. Whether the Detroit Tigers qualified for the FLSA “amusement or recreational establishment” exemption under 29 U.S.C. § 213(a)(3), including whether the batboys worked for a separate, non-exempt establishment.
2. Whether the Tigers were exempt from the Michigan Minimum Wage Law as an amusement or recreational establishment operating no more than seven months per year and open to the public primarily for leisure activities.

## Decision

- The court granted the Detroit Tigers’ motion for summary judgment and dismissed the remaining claims.
- The court held the Tigers satisfied the FLSA amusement/recreation exemption based on seasonal receipts.
- The court rejected plaintiffs’ argument that batboys were a separate establishment; their duties were tied to staging games.
- The court held the Tigers also qualified for the analogous Michigan exemption because operations were seasonal and primarily offered public leisure activities.

## Legal Principles

- Under 29 U.S.C. § 213(a)(3), an employee of an “amusement or recreational establishment” is exempt from FLSA minimum wage and overtime if the establishment satisfies either the months-of-operation test or the seasonal-receipts test.
- Employees performing operational, game-related work integral to producing the recreational event are part of the same establishment for purposes of the exemption, even if much work occurs outside public view.
- Summary judgment is appropriate where the material facts relevant to an exemption (including receipts and seasonal operation) are undisputed and the remaining dispute is a legal classification of those facts.

## Conclusion

The court held that the Detroit Tigers’ stadium operations qualified as an exempt amusement or recreational establishment under both federal and Michigan wage laws and that batboys’ game-support duties did not place them in a separate non-exempt establishment, barring their minimum wage and overtime claims.


Adams v. Detroit Tigers, Inc., 961 F. Supp. 176 (E.D. Mich. 1997)