In Goldberg v. Whitaker House Co-op., Inc., 366 U.S. 28, 81 S. Ct. 933, 6 L. Ed. 2d 100 (1961), the Supreme Court held that members of a knitting cooperative who performed “homework,” were paid on a piece-rate basis to make items for the co-op, and who were subject to expulsion for substandard work, were “employees” of the co-op within the meaning of the Fair Labor Standards Act. The case is important because, inter alia, it applied an “economic realities” test for determining the existence of an employment relationship under the FLSA.