Matter of Yoga Vida

New York Court of Appeals · 2016 · Corporations

64 N.E.3d 276 (N.Y. 2016)

Updated August 22, 2026

CorporationsEmployment classificationUnemployment insuranceindependent contractoremployeeunemployment contributionssubstantial evidencecontrol test

Facts

Yoga Vida operated a yoga studio and used both staff and non-staff instructors, treating the non-staff instructors as independent contractors. The non-staff instructors made their own schedules, chose to be paid either hourly or on a percentage basis, and were paid only if a certain number of students attended their classes. Unlike staff instructors, non-staff instructors could teach at competing studios, could tell Yoga Vida students about classes elsewhere, and were not required to attend meetings or receive training. The Board relied on facts such as Yoga Vida's checking for proper licenses, publishing the master schedule on its website, providing studio space, receiving student feedback, and certain fee and substitute arrangements to find an employment relationship.

Issue

Whether substantial evidence supported the Unemployment Insurance Appeal Board's determination that Yoga Vida exercised sufficient direction, supervision, and control over its non-staff instructors to make them employees rather than independent contractors for unemployment contribution purposes.

Rule

A finding of employment requires record evidence showing that the putative employer exercises control over the results produced and the means used to achieve those results. On substantial evidence review, incidental indicators such as verifying licenses, publishing a schedule, providing workspace, collecting feedback, or requiring work to be done properly do not by themselves establish the necessary control.

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Lakefront Barre Studio in Buffalo classifies certain instructors as independent contractors. Those instructors choose which classes to accept, may teach at competing studios, are not required to attend training, and are paid only if at least six students attend; the studio merely verifies certifications, posts the schedule online, and provides the room.

If the state labor board finds these instructors are employees based only on those facts, what is the strongest argument for reversing that finding?

Explanation. The governing rule is whether the putative employer exercises control over both the results produced and the means used to achieve those results. Under the majority opinion, verifying credentials, publishing a schedule, and providing space are merely incidental indicators and do not by themselves supply substantial evidence of an employment relationship, especially where the instructors retain significant independence.