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Vanskike v. Peters

974 F.2d 806 (1992)

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Vanskike v. Peters

United States Court of Appeals for the Seventh Circuit
974 F.2d 806 (1992)

Facts

Under state law, the Illinois Department of Corrections (DOC) (defendant) was allowed to require prisoners to work. The DOC paid prisoners for their work, but the pay rate was less than minimum wage. The program’s purposes were (1) to promote work habits and skills to rehabilitate prisoners and (2) to offset the costs of incarceration and the work program’s administration. Daniel Vanskike (plaintiff), a prisoner, was required to participate in work assignments that included cleaning, kitchen duty, and fabric assembly. Vanskike sued Howard Peters (defendant), the DOC’s director, in federal district court. Vanskike alleged that the DOC had underpaid him in violation of the minimum-wage provisions of the Fair Labor Standards Act (FLSA) and that the Thirteenth Amendment barred forced prison labor. The district court dismissed the FLSA claim, ruling that, for FLSA purposes, prisoners were not employees and prisons were not employers. The court also dismissed the Thirteenth Amendment claim, finding that the amendment specifically excluded criminal prisoners from its prohibition on involuntary servitude. Vanskike appealed only the FLSA dismissal to the United States Court of Appeals for the Seventh Circuit.

Rule of Law

Issue

Holding and Reasoning (Cudahy, J.)

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