## Facts

- Twenty-five student registered nurse anesthetists (SRNAs) enrolled in Wolford College’s master’s nurse-anesthesia program completed required clinical training at Collier Anesthesia, a private anesthesia practice.
- Florida licensing and the program required substantial clinical experience and completion of numerous anesthesia procedures as a condition of graduation and certification eligibility.
- SRNAs provided patient-care services under supervision of certified registered nurse anesthetists (CRNAs) and anesthesiologists.
- The curriculum contemplated about 40 clinical hours per week, but SRNAs alleged they were often scheduled beyond that and on nonacademic days.
- The parties disputed whether SRNAs displaced paid CRNAs and whether their presence was a net benefit or net burden to Collier’s operations.
- SRNAs brought a collective action under the Fair Labor Standards Act (FLSA) seeking minimum wages and overtime for clinical hours, alleging they functioned as unpaid employees.
- The district court granted summary judgment for defendants, treating the SRNAs as nonemployees under a rigid Department of Labor (DOL) six-factor internship test derived from Portland Terminal.

## Issues

1. What legal standard governs whether students in a degree-linked, graduate clinical program are “employees” under the FLSA.
2. Whether the district court erred by applying the DOL’s six-factor test as controlling rather than a flexible inquiry focused on who primarily benefits from the relationship.
3. Whether summary judgment was proper given disputed facts bearing on educational benefit, scheduling, displacement of paid workers, and the alleged employer’s economic benefit.

## Decision

- The Eleventh Circuit vacated the summary judgment and remanded for further proceedings.
- The court held the district court erred by rigidly applying the DOL’s six-factor test as if it were controlling law.
- The court adopted a flexible “primary beneficiary” test, tailored to modern, education-linked internships and clinical placements.
- The court did not determine as a matter of law whether the SRNAs were employees, emphasizing that the proper test is fact-intensive and the record contained material disputes relevant to that test.

## Legal Principles

- The FLSA employee/intern inquiry turns on who is the “primary beneficiary” of the relationship, evaluated under the totality of the circumstances.
- DOL internship guidance derived from Portland Terminal is not controlling in interpreting the FLSA; it largely restates the specific facts of an older case and does not receive decisive deference.
- Relevant, nonexclusive considerations include: (1) clear understanding of no expectation of compensation; (2) similarity of training to an educational environment; (3) integration with formal education (coursework, credit, degree requirements); (4) accommodation of the academic calendar; (5) duration limited to the period of beneficial learning; (6) whether work complements rather than displaces paid employees while providing educational benefit; and (7) understanding of no entitlement to a paid job at the end.
- No single factor is dispositive; courts must weigh competing educational and economic benefits in context.

## Conclusion

The Eleventh Circuit required courts to use a flexible primary-beneficiary framework, not a rigid six-factor test, when deciding whether students in degree-required clinical placements are FLSA employees, and it remanded because disputed facts prevented proper application of that standard on summary judgment.


Schumann v. Collier Anesthesia, P.A., 803 F.3d 1199 (11th Cir. 2015)