January 2022 - Parks & Recreation - 28

LAW REVIEW
In the case, Adams v. Palm Beach County,
Plaintiffs allege they are entitled to minimum
wage payments under state and federal law.
Public Golf Course Volunteers Make
Minimum Wage Claim
By James C. Kozlowski, J.D., Ph.D.
I
28 Parks & Recreation |
n the case of Adams v. Palm Beach County, 2021 U.S. Dist. LEXIS
191114 a (S.D. Fla. 10/4/2021), Plaintiffs were golf course attendants
at the Osprey Point Golf Course operated by Palm Beach County,
Florida (the County). As part of that arrangement, they were
permitted to play golf for reduced greens fees. Plaintiffs alleged that
they were employees of Palm Beach County and, therefore, entitled to
minimum wage payments under state and federal law. Separately, Plaintiff
Gerald Kasmere alleged that he suffered employment retaliation after he
complained about not receiving minimum wages. In response, the County
filed a motion to dismiss Plaintiffs' lawsuit. In so doing, the County argued
that the Plaintiffs fell within an exception to the minimum wage laws for
public agency volunteers.
Facts of the Case
The County solicited golf course
volunteers through the website for
its parks and recreation department.
The posting for Osprey Point stated:
This is a high volume 27-hole
golf facility that opened in 2010.
The course is the first in Florida
to receive Audubon Certified Classic
Sanctuary status. Volunteers
serve as course rangers, driving
range attendants and bag drop attendants.
Hours vary. Nights and
weekends preferred. Osprey Point
J ANUAR Y 2 0 22 | PARK S ANDRECRE AT ION . OR G
volunteers enjoy being outdoors,
getting to know others with similar
interests and reduced fees to
play and practice golf.
The website further stated in red
print: " This site doesn't provide
court ordered volunteer
hours. "
The website also indicated " an unlimited
number of volunteers are
needed " and " Osprey Point volunteers
enjoy reduced fees to play and
practice golf. "
Plaintiffs performed work at the
direction of, and for the benefit of,
the County at the Osprey Point
Golf Club. They performed duties
as assigned by management,
including being a cart attendant,
ranger, ranger assistant and range
ball picker. They were required to

January 2022 - Parks & Recreation

Table of Contents for the Digital Edition of January 2022 - Parks & Recreation

January 2022 - Parks & Recreation - Intro
January 2022 - Parks & Recreation - Cover1
January 2022 - Parks & Recreation - Cover2
January 2022 - Parks & Recreation - 1
January 2022 - Parks & Recreation - 2
January 2022 - Parks & Recreation - 3
January 2022 - Parks & Recreation - 4
January 2022 - Parks & Recreation - 5
January 2022 - Parks & Recreation - 6
January 2022 - Parks & Recreation - 7
January 2022 - Parks & Recreation - 8
January 2022 - Parks & Recreation - 9
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January 2022 - Parks & Recreation - 12
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January 2022 - Parks & Recreation - 19
January 2022 - Parks & Recreation - 20
January 2022 - Parks & Recreation - 21
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January 2022 - Parks & Recreation - 28
January 2022 - Parks & Recreation - 29
January 2022 - Parks & Recreation - 30
January 2022 - Parks & Recreation - 31
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January 2022 - Parks & Recreation - 33
January 2022 - Parks & Recreation - 34
January 2022 - Parks & Recreation - 35
January 2022 - Parks & Recreation - 36
January 2022 - Parks & Recreation - 37
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January 2022 - Parks & Recreation - 40
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January 2022 - Parks & Recreation - 47
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January 2022 - Parks & Recreation - 49
January 2022 - Parks & Recreation - 50
January 2022 - Parks & Recreation - 51
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January 2022 - Parks & Recreation - 53
January 2022 - Parks & Recreation - 54
January 2022 - Parks & Recreation - 55
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January 2022 - Parks & Recreation - Cover3
January 2022 - Parks & Recreation - Cover4
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