The Tony and Susan Alamo Foundation v. Secretary of Labor case in 1984 revolved around the Fair Labor Standards Act (FLSA) and whether it applied to workers at a religious foundation who were not paid for their labor but received other benefits. The Tony and Susan Alamo Foundation, a non-profit religious organization, operated various commercial businesses staffed by associates of the foundation who did not receive wages but were provided with food, clothing, shelter, and other necessities. The U.S Department of Labor sued the foundation arguing that these associates should be considered employees under FLSA thus entitled to minimum wage and overtime pay. The Supreme Court ruled in favor of the Department of Labor stating that despite being a religious organization or providing basic needs as compensation does not exempt an entity from compliance with labor laws such as FLSA if they engage in ordinary commercial activities.

In the dissenting opinion for Tony and Susan Alamo Foundation v. Secretary of Labor, Justice Powell argued that the majority's decision failed to consider the unique nature of religious organizations and their volunteers. He contended that applying labor laws to these individuals could infringe upon their First Amendment rights by interfering with religious practices. Furthermore, he expressed concern about how this ruling might affect other volunteer-based organizations beyond just religious ones. He also disagreed with the majority's view on what constitutes a "volunteer," arguing that it should be based on an individual’s intent rather than any benefits they may receive in return for their service.