On December 17, 2025, U.S. District Court Judge Yvette Kane granted summary judgment for the U.S. Department of Labor (“DOL”) against the Mennonite Messianic Mission, a church which employed children without pay to care for chickens, chop wood and construct wood pallets for church profit, finding the organization violated the Fair Labor Standards Act (“FLSA”). In doing so, the Court ordered the church to pay approximately $67,000 in back wages to minors and the “mentors” who supervised them at the Liberty Ridge Farm in Juniata County, a facility the church describes as a “rehabilitation center for troubled children.”
In the lawsuit, Walsh v. Mennonite Messianic Mission of Eastern Pennsylvania et al, the DOL alleged that the Mennonite Messianic Mission violated the FLSA by failing to pay the children a minimum wage and overtime, failing to keep proper records, and employing minors in especially hazardous jobs. The church asserted that the children were not employees, but residents of Liberty Ridge and that the mentors were merely volunteers, and therefore, the FLSA did not apply to either category. The DOL argued that the Liberty Ridge farm is “an enterprise engaged in interstate commerce, making over $500,000.00 in revenue from sales of goods produced”.
The Mennonite Messianic Mission further alleged the children’s labor – which included building gates and pallets, repairing tractors, tending to animals, and gardening – constituted vocational training. The Court rejected the church’s arguments and noted that the “undisputed evidence of record demonstrates that the minors did not work for their own personal purpose or pleasure… and did not voluntarily join or participate at Liberty Ridge Farm.” The Court found that the children, some as young as 12 years of age, worked with the implied expectation of compensation in the form of food and shelter during the months and years they worked, qualifying them as “employees” under the FLSA. As for the “mentors”, the record reflected they were paid a $250/month stipend, which the Court found as evidence of working with the expectation of compensation.
Employer Takeaway: At the time of this alert’s issue, it is unknown whether Mennonite Messianic Mission will appeal the decision. The case stands as a reminder that charitable and religious organizations are not exempt from federal and state child labor laws. Regardless of mission or organizational purpose, entities engaging minors in work activities must comply with applicable wage, hour, and safety requirements.
If you have questions about the application of federal or state child labor laws, volunteer classifications, or wage-and-hour compliance, please contact partner Kevin A. Moore or any member of Barley Snyder’s Employment Practice Group.
