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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision
May 18, 1994

the Claim of Angelo v. New York State Association of Learning Disabled

Claimant, a student at the College of St. Rose, sustained an injury during an internship at the New York State Association of Learning Disabled’s Wildwood School. The Workers’ Compensation Board determined an employer-employee relationship existed between the claimant and Wildwood, entitling her to benefits, citing that she performed duties of an unreplaced speech therapist and Wildwood exercised sufficient control. Wildwood appealed, asserting they were denied the opportunity to present testimony to refute the claimed benefits it received from the internship. The Appellate Division reversed the Board's decision, ruling that Wildwood was entitled to a full opportunity to be heard on the factual issues and remitted the case to the Workers’ Compensation Board for further proceedings.

Internship InjuryWorkers' Compensation BenefitsEmployer-Employee RelationshipDue ProcessRight to be HeardRemittalAppellate ReviewSpeech Therapy InternshipUnreplaced TherapistControl Over Performance
References
2
Case No. MISSING
Regular Panel Decision
May 24, 2013

Xuedan Wang v. Hearst Corp.

Plaintiffs, former unpaid interns at Hearst Corporation magazines, moved for partial summary judgment and class certification, alleging violations of the Fair Labor Standards Act (FLSA) and New York Labor Law (NYLL) regarding minimum wage, overtime, and recordkeeping. They sought to certify a class of unpaid interns at Hearst Magazines in New York between February 2006 and the date of final judgment. The Court discussed the applicable legal standards for defining an "employee" under FLSA, considering the "immediate advantage" standard, the "totality of circumstances" balancing test, and the Department of Labor's six-factor test. The Court found genuine disputes of material fact for summary judgment purposes, particularly concerning the nature of the internships, benefits to interns, supervision, and impediment to Hearst's operations. Consequently, both motions were denied, as commonality and predominance requirements for class certification were not met due to the highly individualized nature of the internships across Hearst's various magazines and departments.

Unpaid InternsFLSANYLLWage and HourClass ActionSummary JudgmentClass CertificationEmployee MisclassificationIntern CompensationLabor Law
References
26
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