DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
212626P.pdf 04/26/2022 David Gamble v. Minnesota State-Operated Svcs
U.S. Court of Appeals Case No: 21-2626
U.S. District Court for the District of Minnesota
[PUBLISHED] [Gruender, Author, with Benton and Erickson, Circuit Judges]
Civil Case - Fair Labor Standards Act. Civil detainees who participate in
voluntary Vocational Work Program in the Minnesota Sex Offender Program
sued state defendants that they failed to pay minimum wage under the Fair
Labor Standards Act. Detainees are paid $10 per hour but the state
withholds up to 50% of the wages for the cost of their care. The district
court concluded the detainees were not employees and alternatively that
defendants were immune under the Portal-to- Portal Act. Sexually dangerous
civil detainees are not state employees, there is not bargained-for
exchange of labor for mutual economic gain; detainees are under the
control and supervision of the detention facility; the purpose of the
program is to provide treatment; the program does not generate profits;
the detainees have their basic needs met by the state, including medical
care and meals. The detainees' arguments that used of their labor creates
unfair competition is not convincing, as the program does not provide
goods or services to private entities and program must consult with the
labor market to ensure the activities are in the best interests of the
stakeholders. Because the detainees are not employees, we need not decide
if defendants are immune.