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Two-Part Test Controls if Nonprofit ‘Volunteer’ Is Due Wages

Jan 8, 2026

Div. Five of the First District Court of Appeal has held that a trial judge erred in ordering judgment to be entered in favor of The Salvation Army in a putative wage class action based on a determination that participants in the group’s rehabilitation program, who were required to perform “work therapy” relating to the entity’s collection and sale of donated goods, were exempt volunteers solely because there was no compensation agreement between the parties.