circa 2011. Marilyn Milian, a retired Florida judge and star of The People's Court, taught litigation skills as an adjunct faculty at the University of Miami as of 2013; and musician Wayne Horvitz has worked as adjunct faculty teaching composition at Cornish College of the Arts. Since the 1980s, however, colleges and universities have increasingly utilized adjunct labor, whether full-time or part-time, simply to save money, giving them core undergraduate courses to teach (e.g., introductory math, or freshman-level English composition). Though adjuncts hold at least a master's degree, if not a PhD, the salary for these positions is relatively low. Many adjuncts must work at several schools at once in order to earn a living in academia. Non-tenure-track faculty earn much less than tenure-track professors; median pay per course is $2,700 and average yearly pay is between $20,000 and $25,000. Adjunct pay in state and community colleges varies; however, it can be as little as US$1,400 for a 3-credit hour lecture-based course. At many private institutions on the East Coast, payment for a 3-credit hour course hovers around US$3,000–4,000, with average pay nationwide as of 2014 estimated at around US$2,000–3,000. English professor William Pannapacker noted that adjunct faculty often earn less than minimum wage, when factoring in hours spent on classroom teaching, lesson preparation, office hours, grading of assignments, and other duties. 25% of adjuncts receive public assistance. According to the American Federation of Teachers, "nearly 25 percent of adjunct faculty members rely on public assistance, and 40 percent struggle to cover basic household expenses" and "just 15 percent of adjuncts said they are able to comfortably cover basic expenses from month to month." Some adjunct faculty have remained with the same employer for as long as 25 years without receiving health insurance or retirement benefits. In 2014, Mary-Faith Cerasoli, a homeless female adjunct professor of Spanish and Italian, conducted a protest on the steps of the New York State Education Department Building. Groups supporting the efforts of adjuncts to organize for improved wages and working conditions include the Service Employees International Union, the United Steelworkers, and the New Faculty Majority Foundation. Unionization efforts Increasingly, non-tenure-track faculty are turning to unions, including the American Federation of Teachers, the Service Employees International Union, and United Autoworkers, to improve their wages and working conditions. Adjunct faculty have successfully pushed for contracts at American University, Georgetown University, George Washington University, Howard University, Montgomery