Villarreal v. Woodham’s Empirical Analysis
113 F.3d 202 · 1997
Citation profile
14 federal appellate · 2 state decisions
How this case has been cited
Cited by 42 later decisions — most recently January 2025 · most notably Mark Tourscher v. Martin Horn Secretary of the Pa Dept of Corrections (1999), Wolf v. Coca-Cola Co. (2000)
14 federal appellate · 2 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Bell v. Wolfish · Mt. Healthy City School District Board of Education v. Doyle · Pembaur v. City of Cincinnati · Whitley v. Albers · National League of Cities v. Usery
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“any person acting directly or indirectly in the interest of an employer in relation to an employee and includes a public agency ...”
3 later decisions quote this exact passage · from the majority“Focusing on the economic reality of the situation in its entirety, we conclude that [a pretrial detainee] is not an “employee” under the FLSA. The purpose of the FLSA is to protect the standard of living and general well-being of the American worker. Because the correctional facility meets Villarreal’s needs, his “standard of living” is protected. In sum, “the more indicia of traditional, free-market employment the relationship between the prisoner and his putative ‘employer’ bears, the more likely it is that the FLSA will govern the employment relationship.” Villarreal’s situation does not bear any indicia of traditional free-market employment contemplated under the FLSA. Accordingly, we hold that Villarreal and other pretrial detainees in similar circumstances are not entitled to the protection of the FLSA minimum wage requirement.”
2 later decisions quote this exact passage · from the majority“in light of the 'economic reality' of the relationship between the parties.”
2 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.