6th Circuit Applies “Primary Benefit” Test to Students in Work-Study Program

The United States Court of Appeals for the Sixth Circuit recently held that the proper test for determining whether persons participating in employer-sponsored training programs qualify as “employees” under the FLSA is an examination into which party derives the primary benefit from the relationship. The Sixth Circuit’s decision in Solis v. Laurelbrook provides guidance to any employer using students to perform work as part of a work-study or trainee program who are not monetarily compensated for such work.