Faculty Student Ass’n of State Univ. of Oneonta, Inc. v. Ross, 54 N.Y.2d 462 (1981): Minimum Wage Requirements for University-Affiliated Organizations

54 N.Y.2d 462 (1981)

An organization affiliated with a state university, but not itself a part of the state government or a political subdivision, is not exempt from the state’s minimum wage law for its non-student employees.

Summary

The Faculty Student Association of the State University of Oneonta, Inc. (FSA), a non-profit corporation promoting educational and social relations at the university, was ordered to pay its non-student employees the state minimum wage. FSA appealed, arguing it was exempt as an appendage of the State University, which itself was exempt. The Industrial Board of Appeals revoked the order, but the Court of Appeals reversed, holding that the statutory exemption applied only to the State government or its political subdivisions, and FSA did not qualify. Therefore, FSA’s non-student employees were entitled to the minimum wage.

Facts

The Faculty Student Association of the State University of Oneonta, Inc. (FSA) is a non-profit organization. Its purpose is to foster educational and social connections among students and faculty at the State University. The Industrial Commissioner ordered FSA to pay $355.76 for underpayment to 21 non-student employees because they were not paid minimum wage for specified periods.

Procedural History

1. The Industrial Commissioner ordered FSA to remit payment for underpaid wages.
2. FSA appealed to the Industrial Board of Appeals, arguing exemption from the Minimum Wage Act.
3. The Industrial Board of Appeals revoked the Commissioner’s order, deeming FSA a mere appendage of the State University College at Oneonta, which was exempt.
4. The Appellate Division affirmed the Board’s decision.
5. The New York Court of Appeals reversed the Appellate Division’s order, reinstating the Industrial Commissioner’s original order.

Issue(s)

Whether the non-student employees of the Faculty Student Association of the State University of Oneonta, Inc., are entitled to payment of the minimum wage under Article 19 of the Labor Law.

Holding

Yes, because the Faculty Student Association is not part of the State government or a political subdivision thereof, and therefore does not fall under the statutory exemption from minimum wage requirements.

Court’s Reasoning

The Court of Appeals reasoned that the Minimum Wage Act (Labor Law, Art. 19) applies to non-profit institutions like FSA, requiring employers to pay at least the statutory minimum wage. The term “employee” is broadly defined, with specific exceptions. FSA argued it should be exempt under the exception for individuals employed by a state government or political subdivision. However, the court found that FSA, while affiliated with the State University, is not itself part of the state government or a political subdivision. The court emphasized the statute provides for exemption based on the nature of the employing organization, not its purpose. The court distinguished Matter of Beth Israel Hosp. Housing Co. (Catherwood), noting that the exemption statute in that case was based on the purpose for which the institution was organized and operated, whereas here, the statute focuses on the nature of the employing organization. Therefore, regardless of FSA’s purpose or its relationship to the university, it is not the State government, and its employees are entitled to minimum wage. The court stated, “[I]t matters not for what purpose petitioner is organized, nor that petitioner might be considered a ‘mere appendage’ of the college; since it is not the State government or a political subdivision thereof, its employees do not come within the exception, and therefore are entitled to the minimum wage.”