The U.S. Court of Appeals for the Eleventh Circuit ruled on Monday that an employment law case involving golf course “volunteers” is not ready for appellate review, thereby leaving open the possibility a court could find the volunteers are employees.

Several years ago, the parks and recreation department of Florida’s Palm Beach County posted ads seeking volunteers to serve as course rangers, driving range attendants and bag drop attendance. The ads said that “hours vary” and “nights and weekends preferred.” The volunteers could socialize while working and benefit from “reduced fees to play and practice golf” at Osprey Point Golf Course in Boca Raton and other public courses in the county. They could also receive tips.

The volunteers performed various duties and assignments—such as cleaning golf clubs and loading and unloading golf bags—at the behest of course management. They were also instructed to not sit while on duty. Although not paid a wage, the discounts were significant. While the ordinary greens fee to play at Osprey Point was $96, a volunteer could play for just five dollars, saving $91 savings. The value of the discount added up over time. One volunteer saved $8,645 over a 42-month period; two others saved $3,913 over a seven-month period and $2,821 over a 38-month period, respectively.

Then the COVID-19 pandemic struck, and social-distancing policies altered the volunteers’ workplace-like situation. They could no longer clean clubs or handle golf bags. Tip...

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