Bedford feminists@law, Vol 4, No 1 (2014)

Research Note: Bingo and Feminist Political Economy

Kate Bedford*


Together with two colleagues,[1] I am conducting a three year, Economic and Social Research Council-funded research project into gambling regulation (A Full House: Developing a New Socio-Legal Theory of Gambling Regulation, 2013-6). The project uses bingo to explore the political economy of gambling regulation. Bingo is a game where players cross numbers, called randomly, off a purchased ticket to form patterns and win prizes. It has a distinctive player demographic in many countries, dominated by older, working class women, and it is played in both commercial and non-commercial settings (such as churches, facilities owned by veterans’ organisations, hospitals, and care homes). In its own terms – as a globally salient and distinctive gambling form that often merges playful risk-taking with charity and community – we owe bingo more attention in our critical discussions of the law and political economy of speculative consumption. I provide a basic outline of how the project seeks to contribute to such discussions in section 1. However in this research note I wish to explore specifically what bingo might contribute to our debates within feminist political economy. I hence focus on two further themes:

1. how bingo may contribute to feminist accounts of the governance and regulation of ‘everyday’ risk and speculative consumption (section 2); and
2. how bingo may help take forward critical analysis of volunteering as a specific form of unpaid work (section 3).

Put more simply, I ask what bingo might offer to feminist scholars interested in voluntary risk-taking, and volunteer labour. The project is in its early phases, and hence I am presenting questions and aims rather than findings. However I hope that by relating the research to these themes I can gesture to some ways in which the bingo project may draw from, and contribute to, other efforts to gender discussions of labour, law, and risk regulation.   

Section 1: Project Overview and Methods
Many scholars have analyzed the changing nature of risk regulation in contemporary market economies (Adam, Beck and van Loon 2000; Giddens 1999; Taylor-Gooby and Zinn 2006; Mohun 2013). Gambling is often important in these debates, whether framed as a form of dangerous, unproductive  risk-taking to which new stock market trends are compared (Strange 1986), or used as a site of research into the regulation of risk and speculation in its own right (Neary and Taylor 2006; Reith 2007; Cosgrove 2006; Kingma 2010; Cassidy 2009).

Our project seeks to make a contribution to those debates by focusing on bingo. Bingo is a markedly under-researched site, attracting a fraction of the academic attention given to other gambling forms. The vast majority of research on gambling regulation and political economy is devoted to casinos: they are often positioned, including by those on the left, as the globally salient form of gambling in neoliberal times.[2] Yet in the UK bingo halls outnumber casinos 4 to 1 and employ more people;[3] and in Alabama bingo, not casinos, dominated the 2010 governor’s race (White, Brown and Dowd 2010). More people visit Ontario’s bingo halls than visit Toronto’s iconic CN tower,[4] and when Brazilian President Lula criminalized bingo in 2004 there were protest marches in Rio by players and employees of clubs. In North America bingo has long been a site of struggle for indigenous sovereignty over economic development on reserve land.[5] Yet despite this evidence of the game’s significance, and despite repeated calls – over decades – for more scholarly attention to the sector (Dixey 1987; Downs 2009), bingo remains “relatively virgin territory for researchers” (Chapple and Nofziger 2000, 490).

In particular, we are drawn to bingo as a research topic because it is enmeshed with law and political economy in distinctive ways. It is a key site for charity fundraising, and even when played commercially it is associated with community and social welfare more often than risky profit-making. I have carried out three pilot studies on bingo regulation in Kent (England) and Ontario and Alberta (Canada) showing that regulators struggle to make sense of the challenges posed by this liminal positioning (Bedford 2011). Moreover, this positioning makes bingo the key case for studying how the governance of speculative consumption relates to charity. For example, we can use the game to consider how the regulation of gambling responds to, and is informed by, concerns within charity law about fundraising regulation, and we can look to bingo to reveal how governments see speculation within initiatives to generate community cohesion.

In addition, the project seeks to directly contribute to socio-legal work on gender, risk, and regulation. Little of the research on women's gambling addresses issues of law, regulation, or political economy. Hence the project aims make a distinctive contribution by connecting the study of a key site of working class women’s gambling to research on the gendered nature, and effects, of risk and regulation. Such research has shown that gendered performances of risk-taking may be used by male traders to impress other men (McDowell 2010), in ways that undermine the efficacy of regulation. This project will use bingo as a lens through which to investigate if, and how, gendered assumptions about risk inform the regulation of a feminized gambling sphere, and to advance our knowledge about what attention to gender can bring to current debates about law, regulation, and political economy. 

Using four case studies of bingo regulation (England and Wales; Canada; Brazil; and online play offered to residents of EU member states), the research aims to provide the first systematic account of how bingo is regulated. We have chosen a full range of case studies, involving multiple levels of governance (local/municipal, provincial, national, and transnational). Case studies include places where bingo is run for both commercial and charitable purposes (England and Wales); those where it is almost entirely a charitable domain (Canada); and those where it has recently been made illegal (Brazil). We will ascertain the key legal and policy challenges involved in regulating bingo as experienced by a variety of stakeholders, and make recommendations to policymakers, the bingo industry, third sector organizations, and academics. Key questions include:

  • How, and to what end, is bingo regulated in each jurisdiction? What is the role of charity, criminal, and commercial law? Where is enforcement power located, in law and practice?
  • Are laws governing bingo being relaxed as part of trends towards global gambling liberalization? Is play being standardized, converging towards a global norm?
  • Which rules are most important to various stakeholders, and why? Which are ignored and why? Whose priorities appear to be reflected in new legislation and case law?
  • What are the key regulatory challenges and disputes about? How do various actors understand those challenges, and seek to resolve them?
  • How, if at all, are responsible gambling concerns evident in relation to bingo regulation?
  • How, and to what extent, does it matter to regulators that bingo is part of a gendered gambling culture? Does the female-dominated nature of the game affect its regulation?
  • Which charities and community projects is bingo money used to fund? What relationship do those projects have to bingo players? To the commercial arm of the industry?
  • What strategies, if any, are being undertaken by policymakers to support bingo, and how do these strategies position other stakeholders (the players, the volunteers, the employees etc.)? What accounts for the perceived success or failure of those initiatives?
  • What does the regulation of bingo in different contexts tell us about how governments perceive the role of profit-making within broader community welfare projects?
To answer these questions we will: a) review the current legislation, licensing guidance, and case law shaping regulation of gambling in general and bingo in particular; b) analyze public statements from bingo stakeholders (i.e. in research recommendations on the sector commissioned by regulatory agencies; reports in the national and local press/in online blogs; responses to government or provincial consultations; advocacy from industry associations, charity associations); c) interview key stakeholders involved in bingo regulation d) conduct participant observation in legal bingo games (virtual and land-based) to experience how rules and regulations are interpreted and enforced. Within each case, coding of data will initially follow a simple two stage model: 1) open coding to discover conceptual categories (replicable and sustained, rather than one-off observations); 2) axial coding (relating the concepts to each other in order to develop theoretical categories). In a variation from strict versions of grounded theory (but in line with the coding approach used by other socio-legal researchers – e.g. Webley 2010), this type of coding will proceed both inductively and deductively: we will be able to identify the relationships that emerge from the data itself, and to test how concepts already identified in secondary literature and in the pilot studies (e.g. charity; community; play) relate in this data set. Tentative theoretical models can be tested at this stage, within the case studies. Finally, the open and axial codes that emerge within each case will be compared across cases, and each data set will be explored in the light of the others. Coding processes are hereby comparatively refined, ensuring that the theoretical models that emerge from the entire project are robust within and across sites.

Section 2: Feminist Political Economy and the ‘Everyday’ Edginess of Voluntary Risk-taking
Having outlined the general thrust of the research, I wish to delineate two more specific themes emerging within the bingo project since, we hope, these are relevant to the gendering labour law network. Firstly, we want to use bingo to take forward debates about everyday voluntary risk-taking. Rather than solely understanding risk – and the governance thereof – to be about precaution against catastrophic events, prudence, and profit-making through pre-emption, gambling is a route in to also discussing pleasure, fun, and entertainment. As historian of risk Arwen Mohun (borrowing from Levi–Strauss) argues about rollercoasters, chimneys, and lawn mowers, gambling is “good to think with” (2013, 6), because it draws our attention to processes of vernacular risk culture and regulation. In this regard it relates to research on the concept of ‘edgework’ within sociology, a term used to describe a cluster of activities that involve voluntary risk-taking and danger-seeking (Lyng 2004).[6] Sky-diving, white water rafting, skateboarding, and mountaineering have all been explored as various forms of ‘edgework’.

‘Edgework’ is useful as a concept because it centres the dual, intertwined nature of risk regulation – as involving both the control of perceived deviance, and the production, commodification, and shaping of desires for transcendence, freedom, escape, self-mastery, and authenticity. Having a genuine stake, or something at risk, in these activities is key to their appeal. Although the majority of people interviewed in one large study of internet gambling saw it in terms of leisure, entertainment, and recreation, the fact that their money was at stake was also key. As one man put it, “playing for fun takes the fun out of it” (quoted in Parke et al. 2012, 151).

In this respect I am drawn to research that has tried to connect up various forms of voluntary risk-taking with political economy, regulatory norms and institutional orders (Lyng 2004; Mohun 2013; Reith 2007), especially as these relate to the commonplace, the vernacular, or the everyday.[7] While some see edgework in terms of self-determination, control, resistance, and escape from the mundane, others have explored the synergies between the mundane and the edge, or between edgework practices and everyday institutional orders (e.g. Langley 2007; Lyng 2004). For example, Jonathan Simon has shown that voluntary risk-taking is increasingly what governing institutions expect of people (Simon 2004, 206). Skills to cope with radical normative under-determination, and knowledge of how to respond to risks without the shelter of comprehensive institutional risk-spreading systems, are increasingly prized.[8] The labour involved in edgework is of particular interest in this regard. While many have examined the skill of riding the ‘edge’ between life and death involved in extreme sports, others have examined the skills involved in managing the more mundane consumption of risk. For example sociologists Holyfield, Jonas, and Zajicek have charted the micro-level practices of white water rafting guides as they labour to create illusions of risk while never actually endangering the customers on whose tips they rely (Holyfield, Jonas, Zajicek 2004, 184; see also Mohun 2013 on designers and operators of early amusement rides).

In the bingo project, I seek to re-visit the edgework literature using a seemingly mundane, unglamorous site that appears to be very far away – experientially and analytically - from sky diving, or even commercialized white water rafting. I do this out of a sense that the mundane and unglamorous are especially vital research sites for those of us interested in critical political economies of leisure and consumption (see especially Peiss 1986). As Edensor et al. argue in their collection on Spaces of Vernacular Creativity (2010), there is a stark need for a range of scholars to intervene critically in conversations about creativity and political economy, especially when these coalesce into a ‘creative cities’ ideology that privileges the cool, urban young as gentrification instruments. Cool is a class articulation, as well as being an articulation of gender, race, and age (Edensor et al. 2010, 7), wherein specific forms of urban development are championed and parallel ‘cultural wastelands’ – both within otherwise cool cities and outside them – are produced  (Edensor et al. 2010, 1). There is an urgency, then, to exploring the suburbs, the ‘crap towns’ (Edensor et al. 2010, 5-6), the everyday context of economic crisis (Shevchenko 2009), the gnome collections (Potts 2010), to better understand the vernacular and everyday landscapes of creativity. Such landscapes are not spectacular, or extraordinary – in fact they are often explicitly self-effacing:

“vernacular creativity foregrounds the un-hip, the un-cool, and possibly the downright square, and embraces those marginal and non-glamorous creative practices excluded from arts- and culture-based regeneration” (Edensor et al. 2010, 10).
I am especially keen to explore what bingo can teach us about the unglamorous, unspectacular types of edgework and playful speculation in which older, working class women engage, and to hereby intervene critically in the exclusionary logics that attend much research and policy around culture and regeneration.

However, the project is not an ethnographic one, and it seeks to make explicitly regulatory interventions. In Edensor et al.’s framing, vernacular creativity allows a focus on the value of practices that do not produce commodifiable economic products, but that might instead produce community cohesion, neighbourhood identity, or conviviality (Edensor et al. 2010, 11). I worry slightly that such a framing may prove insufficient for exploring the everyday institutional orders that co-constitute these practices – the norms of sharing winnings between tablemates, the council zoning rules or provincial laws on fundraising, or the “lowly legal mechanism of licensing” (Valverde 2011, 297). Rather, in keeping with feminist political economic analysis (Rai and Waylen 2008), I am interested in probing how community as a political-economic formulation is regulated, produced, and resisted in the bingo realm. Indeed, precisely because bingo straddles boundaries between charity and business, and because it is so closely associated with non-profit activity, the game allows us to explore how regulators, businesses, charities, workers, and players value what is produced in this space of vernacular creativity, and how the regulatory framework is in turn informed by those attributions of value.

Section 3: Unpaid Work and the Charity/State Nexus
The second set of feminist political economy conversations to which the bingo project seeks to contribute involve the promotion and regulation of unpaid work. As noted above, bingo is a paradigmatic example of how gambling can involve fundraising for good causes. Notwithstanding the tendency of many popular accounts of gambling to fixate on spectacles of high-rolling roulette players in casinos, charitable gambling is, in fact, “the most widespread form of legalized gambling” (Dolan and Landers 2006, 6) in many countries, including the US and Canada. More specifically, many jurisdictions that grant licenses for charitable bingo – including most Canadian provinces and US states – require the game to be run by volunteers. This requirement makes bingo a key case study for those trying to better understand the legal mediation of the world of volunteer labour. Hence the project asks what we learn about the governance and regulation of bingo volunteers – by charities and states – when we explore this concrete site of unpaid labour.

Formal volunteering is a subset of unpaid work, usually distinguished from other types on the grounds that it is done for altruistic reasons, for organizations (as opposed to informally, for family and friends).[9] Charity law specialist Debra Morris defines volunteering as “the commitment of time and energy for the benefit of society or the community” (1999, 249 emphasis added). Volunteering has been identified “a lost continent” of social life (Saloman et al. 2000, quoted in Mohan et al. 2006, 267), since so little is known about its patterns and determinants, its socio-legal regulation, or its meaning to participants.[10] Of course attention to unpaid work is long-standing in a range of legal sub-fields, including labour law, welfare law, and charity law (Morris 1999; Mahood 2009; Kelley 2005). Moreover, unpaid work has long been of interest to feminist scholars exploring the gendered limits of mainstream political economy. Unpaid work to sustain community life is included in most feminist definitions of social reproduction (Bedford and Rai 2010; Bakker and Gill 2003; Alessandrini 2014), and there are many accounts of the gendered, classed, and racialized nature of this work (Lind 2005; Molyneux 2006; Gilmore 2007; Dolhinow 2010). We also know from decades of research on structural adjustment that women are often enlisted as ‘volunteers’ to sustain communities in the face of state withdrawal (Bakker 1994; Sparr 1994).

However when volunteers have appeared on the radar of mainstream legal study they have done so mostly in relation to debates about whether they can claim employee status (Morris 1999). When they are determined to fall outside that status – sometimes, tautologically, because they are associated with an organization with a charitable or religious purpose – interest often wanes.[11] Hence much debate on volunteers in Canada concerns the fear that charities, businesses, or state agencies will inadvertently treat volunteers in such a way as they can claim employee status.[12] In addition, many charities are concerned about their liability for vicarious torts; in Canada, volunteer screening is being promoted federally as a national response (Volunteer Canada/Public Safety Canada 2012).[13] Some charities are also fearful that human rights legislation imposes too high a level of protection for volunteers against alleged discrimination.[14] However there is a distinct need for research which centres volunteers themselves (rather than regulators and charities) as key stakeholders.

The urgency of such research has grown in recent years. Political – and sometimes legal – battles over (in)voluntary work have become key features of welfare state restructuring in several countries,[15] as a result of pressures placed on people to perform unpaid labour in exchange for benefits, the expanding use of internships for young people seeking training and access to paid work (Stewart and Owens 2013), and the key role played by volunteers in sustaining charitable organizations as they are contracted to pick up the slack of state cuts.[16] In particular, many scholars and activists – feminist and otherwise – associate the revival of voluntarism with contemporary neoliberalism wherein the poor are responsibilized through charity – including through providing unpaid labour to charities – rather than being entitled to benefits as welfare state citizens (Brooks 2001; Gilmore 2007; Raddon 2008). The complex relationship between charities, businesses, and state actors – always of interest to critical charity analysts[17] and sometimes of interest to courts[18] – has hereby become a core concern when analyzing voluntarism.

The bingo project is broadly located within this critical debate about charities and neoliberal trends in social policy. However it takes the lead from those authors who have urged attention to the experiences of volunteers in specific localities (Milligan and Conradson 2006). It hereby seeks to complement work on the production of voluntary sector spaces;[19] the diverse meanings that volunteering holds for those who engage in it, and the social relations – including the class and gender relations – made possible, and challenged, by the mobilization of unpaid labour for altruistic purposes. While some forms of voluntarism involve wealthy people engaging in a form of poverty tourism, temporarily trying out new roles such as food server in a homeless shelter, or amateur shopkeeper (Prochaska 1977), as Linda Mahood (2009) notes, volunteering can also provide a source of adventure and rebellion, and opportunities to travel, form intimate communities with likeminded people, and express political opinions. Women’s engagement in philanthropy provided some of them with an activist outlet and a route to escape domestic life. Moreover, research on low-income volunteers suggests that the meanings of unpaid work may vary considerably from the standard middle class narrative of volunteering to build a c.v., or discover oneself through working with the poor. Kenneth Maes’s interviews with unpaid carers for people living with HIV/AIDS in Addis Ababa found that motivations ranged from reducing suffering and pleasing God, to desires for direct remuneration (such as food), new knowledge, patron-client relationships, and paid job opportunities in a context of widespread unemployment and poverty (Maes 2012, 55). The NGOs that organize these volunteers try – never entirely successfully – to shape these motivations, a reality that “recasts economically-insecure volunteers’ consent to donate their labour as a process of negotiation with their organizers” (Maes 2012, 54).

Liz Parsons’ research on charity shop volunteers offers another useful analysis of how the meaning of unpaid labour can be impacted by shifts in regulatory approach, themselves related to political economic trends. She found that UK charity shops created spaces for sociality and belonging in the local community, especially for older women volunteers (Parsons 2006, 236). Those volunteers saw the main beneficiaries of their labour as the shoppers (local poor people who were in need of a bargain), rather than those abroad that the charity was aiding through its global humanitarian and development activities. This localized ethos of helping people with whom there was a perceived common bond was harmed as charities moved to professionalize the shops, making them more traditionally work-inflected sites with paid managers at head office level, increasing standardization of displays, and, in some cases, a move to uniforms and/or name badges (Parsons 2006, 231).

The bingo project aims to continue this thread of research into how shifts in regulatory approach, themselves related to political economic trends, affect volunteer motivations and experiences. In particular, we want to understand better how the volunteers whose labour sustains charitable bingo games are regulated and incentivized, by both charity and state actors (whether at local, municipal, provincial, national, or transnational level). We hereby seek to explore the nexus of charity and state power as evident in the realm of charitable gaming, in part to learn more about how volunteer labour is mobilized. In particular, keeping in mind the lessons from literature on the diverse meanings that volunteering holds for those who engage in it and on the constantly evolving – but likely never entirely successful – efforts by charities and governments to delimit and control those meanings, we hope that bingo can contribute to the broader imperative of exploring resistant narratives of voluntary work – especially by working class women.

Conclusion: Research Reflexivity and our Everyday Debt
The bingo project hopes to offer some insights to feminists interested in the everyday institutional landscape of voluntary risk-taking, and volunteer labour. Notwithstanding the fact that the findings are several years away, we are orienting the research questions to address core concerns within feminist scholarship, including about gender and risk, unpaid work, and regulation of community. However, the project is also informed by a commitment to feminist research methods and epistemologies, including a valuing of and attentiveness to the production and regulation of unglamorous, mundane spaces, and a critical curiosity about the structuring of production and social reproduction in various places. In this way we hope to make some contributions to the gender scholarship that has, in turn, laid the pathway for our research.

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* Dr Kate Bedford, Reader in Law, Kent Law School, University of Kent, UK, email

[1] Dr. Oscar Alvarez-Macotela, and Professor Toni Williams. The research team includes diverse expertise, including in law and development, gender and regulation, financial law, consumer law, and feminist political economy.

[2] See Cassidy (2009) for a critique.

[3] In late 2010 there were 784 UK premises licensed to offer bingo (compared with 145 licensed casinos), and bingo halls employed 17,896 people (compared to 13,094 employed by casinos) (Gambling Commission 2011, 16).

[4] Fieldnotes from e-bingo marketing presentation, Ottawa, 2009.

[5] E.g. the Seminole tribe contested the state of Florida’s attempts to restrict high-stakes bingo games on its land, prompting litigation that eventually resulted in the 1988 Indian Gaming Regulatory Act (Pub.L. 100-497, 25 U.S.C), the federal legislation that governs state-tribe gaming compacts in the U.S. Bingo played a key role in the conflict over gambling and jurisdiction in the Mohawk territory of Akwesasne (Johansen 1993), one result of which was the establishment of internet gaming services on the Kahnawá:ke territory (Belanger 2011).

[6] Sometimes people who study ‘edgier’ forms of deviance object to gambling being placed in the same category of voluntary risk-taking as sky diving, because they characterize gamblers as accepting fate rather than aiming for self-mastery through skillful manipulation of risk. See Reith (2004, 243) for an effective counter-argument.

[7] Mainstream political economy scholars are also now looking to the ‘everyday’ as a key site (Hobson and Seabrooke 2007), drawing (sometimes without sufficient acknowledgement or engagement) on a long tradition of feminist work. See, inter alia, Elias (2010); LeBaron (2010); and Weber (2010).

[8] In a brilliant essay on the popularity of Alpinism among Victorian barristers, Simon also shows that those groups who are most drawn to performative spectacles of risk-taking can be those whose are actually best protected from the political economic risks they unleash on others. The Alps were a fantasy space for lawyers to project, and experiment with, emerging principles of Victorian capitalist risk governance while at home they enacted strict protections to guard their own profession against competition (Simon 2004, 206)

[9] On the distinction between formal and informal volunteering see, inter alia, Skinner and Rosenberg (2006).

[10] Research on the economic contribution made by the non-profit sector often imputes economic value to volunteer labour time. However we know little about the socio-legal regulation of their labour.

[11] Volunteers often fail the employee test because specific exemptions have been made for charitable organisations. Even when they have not, courts are generally reluctant to probe deeply into labour relations in charities: as Stewart and Owens note: “in Australia generally it has been difficult to perceive a strong policy approach to the interpretive task performed by courts [about whether an employment contract exists for unpaid workers] (absent perhaps a reluctance to find employment relations in relation to charitable, religious, or sporting organisations)” (Stewart and Owens 2013, xvi, emphasis added).

[12] Some volunteers (especially fire fighters) have been considered employees for the purposes of provincial employment legislation and insurance and worker’s compensation benefits (Volunteer Canada/Public Safety Canada 2012). A variety of groups offer legal advice to charities and businesses – especially businesses in the tourism sector – to reduce the ‘risk’ that volunteers inadvertently become employees. See Go2 Tourism HR Society (2013). See Morris (1999) for similar fears in the UK by the National Council for Voluntary Organisations.

[13] The implications of this screening for the expanded reach of criminal justice are profound: see Hannah-Moffat, Maurutto and Quirouette (2013).

[14] In 2011 I attended a day-long seminar for non-profit organizations on Canadian charity law which returned several times to this issue. Charity lawyers explained how Christian organizations could draft volunteer duty specifications such that they could legally exclude gays and lesbians from volunteering.

[15] On the U.K. see R (on the application of Reilly and another) v Secretary of State for Work and Pensions [2013] UKSC 68. In Canada see Gosselin v. Québec (Attorney General) 2002 SCC 84, [2002] 4 SCR 429, where the majority dismissed a class action suit brought by a welfare recipient against a 1984 Québec social assistance scheme that set the base level of welfare payments for those under 30 at one third of the rate given to those over 30, and required participation in education or training programmes to boost the benefits level. Several other provinces, including Alberta and Ontario, also enacted workfare schemes as part of welfare reforms: e.g. the Ontario Works Act (1997, S.O. 1997, c.25).

[16] For example, during the UK’s 2012 Jubilee holiday a charity with a contract for job training under the government’s increasingly punitive welfare regime used unpaid workers to help steward the celebrations. The volunteers reportedly slept under Thames bridges until their labour – for private security firm Close Protection UK – was required (BBC 2012).  

[17] E.g. see Harring (1976-7) on the role of Buffalo’s Charities Organization Society in the violent police repression of local labour movements in the late 1800s, in the interests of business owners. See Maurutto (2003) on how philanthropic institutions have modelled themselves on capitalist enterprises. See Rekart (1993) on the intertwining of state and charity in B.C., and Wolch (1990) on voluntary organizations as a ‘shadow state’.

[18] E.g. Alamo Foundation v. Secretary of Labor 471 U.S. 290 (1985), where the US Supreme Court found that workers in the businesses of a non-profit religious foundation were employees for the purposes of the Fair Labor Standards Act, and were hence covered by minimum wage and overtime provisions. The workers were mainly indigent people offered ‘rehabilitation’ through the foundation. They worked for little or no pay and were punished for poor job performance or absence, including via withholding of food. 

[19] E.g. Valins (2006) on the role played by Jewish care home volunteers in creating a sense of ‘home’ for residents.


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