Presumably buoyed by the district court ruling in Glatt v. Fox Searchlight Pictures Inc., 2013 U.S. Dist. LEXIS 82079 (S.D.N.Y. June 11, 2013), a number of copy-cat lawsuits have been filed by former entertainment industry interns in recent weeks in the Southern District of New York’s Manhattan courthouse seeking unpaid wages. Salaam, et al.

While it is understood that the FLSA applies to any “employee” employed by an “employer”, numerous courts have observed that this analysis does little to flesh who is an “employee”. In a recent appellate decision highlighting such difficulties, the Court of Appeals for the Sixth Circuit held students enrolled in a vocational training program at an