Mayo Foundation for Medical Ed. and Research v. United States (09-837)
argument 09-837Mayo Foundation for Medical Ed. and Research v. United States
Supreme Court of the United States
44 min
4 speakers
8 chapters
transcribed 7 days ago
official recording ↗
Transcript
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What is the Supreme Court case being argued and why is it significant?
We'll hear argument next in K09837, Mayo Foundation for Medical Education and Research versus the United States. Mr. Olson.
Mr. Chief Justice, and may it please the Court, Congress expressly exempted from Social Security taxes wages paid to a student who is enrolled and regularly attending classes. The medical residents at petitioner schools are are enrolled and pursuing a formal accredited curriculum that has a rigorous core curriculum, as I said, hundreds of classes, conferences, lectures, laboratory research, written exams, grades, and intensive hands-on clinical patient training under the supervision of faculty members.
Mr. Olson, our Are all institutions that employ residents schools?
I don't know whether all — as I understand, the resident program, which is accredited by the Accreditation Council for Graduate Medical Education, does involve an accreditation program which would probably fit where it's taking place would probably fit the definition of schools. That is certainly not an issue in this case. There are these — the institutions that we represent
— JUSTICE SOTOMAYOR Well, it might — it might be relevant, because it would be unseemly, perhaps, to have residents who are not working at, quote, schools, subject to the FICA tax, and other residents whose training is approximately the same, escape the tax.
Well, that was a judgment that Congress made. Congress made the exemption with respect to students, and it tied specifically in to someone who is enrolled and regularly attending
classes. But you can't give me the reality that are all resident programs conducted in schools, or are there resident programs that would not qualify because they take place in institutions The
only reason I'm hesitating, Justice Ginsburg, is I don't know the entire universe out there. Every program, residence program that's been involved in the various cases that have discussed this have been at schools, universities or colleges. I'm aware of no program that involves residency and residence programs accredited by the ACGME that is not involved and does not take place in a school or university or college. It could be something out there that I'm not aware of, but I'm not aware of anything of that nature. It is undisputed that these individuals in these residence programs are enrolled and that they are regularly attending classes by various definitions of the word class. The clinical experience that they are receiving in hospital rooms, in lecture halls, in all the circumstances that they're involved in are educational and
They are classes, and it is undisputed, undisputed that the purpose of these programs is to educate doctors so that they can achieve board certification and hospital programs.
Mr. Olson, are residents supervised their entire 40 to 80 hours? Is there an attending physician standing over their shoulder and looking at what they're doing?
Well, there's — There's two parts to that question. The answer to the second part is, of course not. There is not a supervising attending physician standing over their shoulder at every moment, but they are being supervised all of the time during their residency program. That is to say that the work that they do is under the supervision, in that broad sense, of an attending physician who looks over what they do, comments on what they do, and so
forth. How I look at this case is, is how do you draw the line between a student who is working and a worker who is studying? So the issue for me is, is the Treasury Department's identification of how to draw that line unreasonable? Do we owe them deference? Let's use the example that's been floated around the briefs. The general counsel of the university who takes classes to increase his knowledge, is he a student who is working or is he a worker who's
studying? Well, the various courts that have considered this have found the statutory provisions that Congress has spoken to the subject. It has provided an exemption for students and it has provided its own limitations. You have to be enrolled and regularly
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Chapters
8 chapters
1
What is the Supreme Court case being argued and why is it significant?
0:02–6:30
2
How does Congress define a “student” for the Social Security tax exemption?
6:30–11:32
3
Why do medical residents argue they should be treated as students under the exemption?
11:32–16:41
4
What is the Treasury Department’s “predominance” test and how does it differ from Congress’s language?
16:41–22:01
5
When should courts give deference to the IRS regulation – does Chevron apply?
22:01–26:46
6
How would classifying residents as employees affect Social Security coverage and benefits?
26:46–33:01
7
Do hypothetical work‑study scenarios (e.g., two paid hours vs. eight unpaid hours) change the analysis?
33:01–39:14
8
What are the parties’ final arguments and what outcome are they seeking from the Court?
39:14–44:15