Adams v. Detroit Tigers, Inc.

961 F. Supp. 176 (1997)

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Adams v. Detroit Tigers, Inc.

United States District Court for the Eastern District of Michigan
961 F. Supp. 176 (1997)

Facts

Troy Adams, David Ruolo, Wayne Carlisle, and Shawn Adams (batboys) (plaintiffs) were batboys for the Detroit Tigers, Inc. (club) (defendants) during the 1992 through 1995 baseball seasons. Seasons typically ran for seven months between April and October. During each home game at Tiger Stadium, one batboy would take a turn to perform on-field duties in uniform, while the others would work in the dugout by, among other things, answering the phone and running errands. In addition, all batboys performed off-field work, like passing out towels and uniforms and cleaning spikes. The club operated in a limited capacity during the offseason, but Tiger Stadium was closed to the public between November and March. The batboys sued the club for violating the federal Fair Labor Standards Act (FLSA) by not paying the minimum wage or overtime. The club moved for summary judgment, arguing it was exempt under the act as a recreational or amusement establishment that did not operate for more than seven months in a calendar year or because it had average receipts for any six months of a calendar year that were less than 33.3 percent of its average receipts for the rest of the year. The batboys did not dispute that the club was a recreation or amusement establishment or the evidence regarding its monthly receipts. Rather, the batboys argued they were a separate establishment within the club. That is, the batboys claimed that because they performed nonpublic work, they were comparable to a sport team’s administrative workers, who, according to an opinion letter by the wage and hour administrator of the Department of Labor, were a separate establishment to which the general public did not have recourse.

Rule of Law

Issue

Holding and Reasoning (Cohn, J.)

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