The Court's opinion really came down to three main points:
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- The Court decided not to apply the standard multifactor tests for analyzing whether an employment relationship existed because the multifactor test "fail[s] to capture the true nature of the relationship";
- The Court then noted the "long-standing . . . tradition of amateurism" in college sports; and
- The Department of Labor "Field Operations Handbook" specifically excludes "extracurricular activities" from its definition of employment, with a cross reference to a mention of "interscholastic athletics."
And that's pretty much it. I don't think I'm oversimplifying the Court's opinion here.
I do think the Court oversimplified the analysis, and some review of the traditional multifactor test would have been informative. That's not to say that I think they reached the wrong result - to the contrary, I suspect this is the correct outcome - it just felt a little underwhelming. In fairness, the Court was deciding this case at the pleadings stage and therefore had virtually no record on which to base such analysis.
Endnote: In a concurring opinion, Judge Hamilton notes that the plaintiffs were non-scholarship athletes in a non-revenue-generating sport (UPenn Track and Field). The "economic realities" may result in a different outcome for scholarship athletes in revenue-generating sports.