In County of Los Angeles v. WCAB (Duke) (1974) 39 CCC 809, the Court of Appeal denied the County of Los Angeles' petition for review of an Appeals Board decision that a welfare recipient who was required to perform certain office duties by the County as a condition for receiving welfare was an employee of the County at the time of her injury. In Duke the claimant of workers' compensation benefits was a recipient of county welfare and was required to perform services for the County of Los Angeles at an information desk in a county building. She received county relief based upon her need and was only required to work for the number of hours it would take her to work off the total amount of the aid at the federal minimum wage rate. The workers' compensation referee (now called workers' compensation judge) held that the claimant was an employee of the county as: (1) the injured was not a "volunteer" because she did not freely consent to perform services for the county; (2) the county was not within the charitable relief exclusion of Labor Code Section 3352; (3) claimant was assigned to work for the purpose of rehabilitation with the ultimate goal being her permanent removal from the welfare rolls and therefore she was not performing services for "aid or sustenance only"; (4) her work was similar to that of an "apprentice" or a "person undergoing rehabilitation" both of which classifications are covered by the workmen's compensation laws; (5) the county treated job training programs differently from work and relief programs. In Duke the Board denied reconsideration and affirmed the referee's decision.