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William M. Nicastro v. Janet Reno
Citations: 84 F.3d 1446; 318 U.S. App. D.C. 72; 3 Wage & Hour Cas.2d (BNA) 526; 1996 U.S. App. LEXIS 12860; 1996 WL 284797Docket: 95-5152
Court: Court of Appeals for the D.C. Circuit; May 31, 1996; Federal Appellate Court
Federal prisoners working for Federal Prison Industries, Inc. (FPI) are not classified as "employees" entitled to minimum wage under the Fair Labor Standards Act (FLSA). William M. Nicastro and Roy D. Little, federal inmates, sought minimum wage compensation for their work at FPI, but their claim was dismissed by the district court, which the Court of Appeals affirmed. The court relied on the precedent set in Henthorn v. Department of Navy, which defines an "employee" under the FLSA as an individual who has "freely contracted with a non-prison employer" for their labor. The court found that the work performed by the inmates is not voluntary; federal law mandates that all able-bodied prisoners work. While inmates may choose to work in FPI instead of institutional jobs, this does not equate to voluntarily contracting their labor. Additionally, FPI is classified as a government corporation, meaning it does not qualify as a "non-federal employer." Its funding comes from the U.S. Treasury, and it operates under regulations from the Attorney General regarding inmate compensation. Consequently, the court concluded that Nicastro and Little's claims do not satisfy the criteria for employee status under the FLSA, leading to the dismissal of their complaint.