While the large class action unpaid intern wage and hour suits against Hearst Corp. and Fox Entertainment Group are still pending or have settled, the 11th Circuit recently sided with the employer-defendants in a case raising similar issues.

In Kaplan v. Code Blue Coding and Billing, students in MedVance Institute’s Medical Billing and Coding Specialist program, which required all students to complete an externship after finishing their other course work, filed suit against employers where they served their externships seeking minimum wage. They claimed that given the lack of formal structure and the repetitive nature of the work, they received very little educational benefit from their externships and instead the defendants benefitted from their work