In the case of Donovan, Secretary of Labor, et al. v. Richland County Association for Retarded Citizens (1981), the U.S Supreme Court was asked to determine whether certain employees were exempt from minimum wage requirements under section 13(a)(10) of the Fair Labor Standards Act (FLSA). The Richland County Association for Retarded Citizens operated a sheltered workshop where mentally disabled individuals performed various tasks and received sub-minimum wages. The Department of Labor argued that these workers should be covered by FLSA's minimum wage provisions because they were "employees" engaged in commerce or in the production of goods for commerce. However, the association contended that their activities did not constitute "commerce" as defined by FLSA and thus they fell within an exemption provided by section 13(a)(10). Ultimately, it was ruled that these workers were indeed involved in commerce and therefore entitled to federal minimum wage protections.

In the dissenting opinion for Donovan v. Richland County Association for Retarded Citizens, Justice William Rehnquist argued that the majority's decision to apply minimum wage and overtime provisions of the Fair Labor Standards Act (FLSA) to sheltered workshops was misguided. He contended that such facilities were not designed as profit-making enterprises but rather served a humanitarian purpose by providing therapeutic or rehabilitative services to individuals with intellectual disabilities. Therefore, they should be exempt from these labor laws. Furthermore, he expressed concern that applying FLSA standards could potentially harm these institutions financially and limit their ability to serve this vulnerable population effectively. Ultimately, he believed it was Congress' role - not the courts' -  to determine whether changes in societal attitudes towards disability warranted alterations in labor law application.