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7th Circuit Says Beauty School Student Not An Employee

On September 5, 2017 by Schnader

On August 14, in Hollins v. Regency Corp., the Seventh Circuit Court of Appeals affirmed a decision from the U.S. District Court for the Northern District of Illinois that a cosmetology student who worked at her beauty school’s salon was not an employee of the school. Regency Corporation operates for-profit cosmetology schools in 20 states. Regency requires that students complete 1,500 hours of classroom and hands-on work, which they accomplish by working in the school’s salon. Customers pay discounted prices. The students are not paid, but receive licensing hours and academic credit.

Venitia Hollins claimed her work at the school salon was compensable under the Fair Labor Standards Act (FLSA). She brought a collective action under the FLSA and a class action under state statutes. The district court granted summary judgment for the school on liability and denied Hollins’s motion for conditional class certification as moot.

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