Osborne v. Salvation Army‪.‬

In October, 1937, the defendant, The Salvation Army, was the owner of a building at 535 West 48th Street, in New York City, and there conducted a home for unemployed and destitute men where they were furnished with board and lodging. The men were not required to pay anything but were required to perform work that might be assigned to them in the nature of housecleaning in the building in which they were living. The purpose of this is said to have been "to maintain the morale, self-reliance and self-respect of the men" and to enable the defendant to distribute its "charity over the largest possible area and take care of the largest number" (fol. 261).