Schumann v. Collier Anesthesia, P.A.

803 F.3d 1199 (2015)

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Schumann v. Collier Anesthesia, P.A.

United States Court of Appeals for the Eleventh Circuit
803 F.3d 1199 (2015)

Facts

A group of student registered nurse anesthetists (SRNAs) (plaintiffs) attended Wolford College (Wolford) (defendant) to obtain master’s degrees that would qualify them as certified registered nurse anesthetists (CRNAs). Under Florida law, the curriculum required the SRNAs to participate in 550 surgical procedures over the course of four semesters. The SRNAs obtained some or all of their clinical experience at Collier Anesthesia, P.A. (Collier) (defendant). The Wolford curriculum contemplated 40 clinical hours per week, but Collier routinely scheduled the SRNAs for more than that and during nonacademic days. The SRNAs were supervised and evaluated by CRNAs or anesthesiologists. There was conflicting evidence as to whether Collier reduced the number of CRNA hours scheduled in favor of scheduling unpaid SRNAs and whether the use of SRNAs was more of a burden or benefit to the practice. The SRNAs filed suit under the Fair Labor Standards Act alleging that they were owed unpaid wages and overtime pay on the grounds that they were employees of Collier. The district court found that the SRNAs were not employees and entered summary judgment in favor of Wolford and Collier.

Rule of Law

Issue

Holding and Reasoning (Rosenbaum, J.)

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