The plaintiff, a volunteer firefighter, appeals from the district court's dismissal of her claim of sexual harassment under Title VII of the Civil Rights Act of 1964. The threshold-remuneration test is used to assess a plausible employment relationship within the volunteer context. Common law principles are used to analyze the character of an economic relationship only in situations that plausibly approximate an employment relationship. The plaintiff here is not an "employee" within the meaning of Title VII. The district court's dismissal is affirmed. 5th U.S. Circuit Court of Appeals, No. 12-30274, 05-30-2013.
Juino v. Livingston Parish Fire District No. 5
June 5, 2013