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Glatt v. Fox Searchlight Pictures, Inc.

791 F.3d 376 (2015), 811 F.3d 528 (2nd Cir. 2016)

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Glatt v. Fox Searchlight Pictures, Inc.

United States Court of Appeals for the Second Circuit

791 F.3d 376 (2015), 811 F.3d 528 (2nd Cir. 2016)

Facts

Eric Glatt, Alexander Footman, and Eden Antalik (plaintiffs) were hired as unpaid interns for Fox Searchlight Pictures, Inc. and Fox Entertainment Group (Fox) (defendants). Glatt and Footman interned in various departments associated with the Fox Searchlight-distributed film Black Swan, and Antalik interned at Fox Searchlight’s corporate office. In 2011, Glatt, Footman, and Antalik sued Fox in federal district court, asserting that Fox violated the Fair Labor Standards Act (FLSA) and New York Labor Law by not paying them as employees during their internships as required by the statutes’ minimum-wage and overtime provisions. Glatt and Footman moved for partial summary judgment on the issue of their employment status, asserting that Fox had improperly classified them as unpaid interns instead of as employees. The district court granted the motion, and Fox appealed to the United States Court of Appeals for the Second Circuit.

Rule of Law

Issue

Holding and Reasoning (Walker, J.)

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