Bryson v. Middlefield Volunteer Fire Dep't, No. 10-3055 (6th Cir. 2011)
Annotate this CasePlaintiff became a firefighter-member in the department in 1991 and also became an administrative assistant in 1997. She alleges that defendant, fire chief until 2005, subjected her to unwanted sexual advances and verbal and physical contact of a sexual nature. She filed charges with the Ohio Civil Rights Commission and the Equal Employment Opportunity Commission in 2004. In 2006 the EEOC determined that firefighter "members" are employees, even if not paid, and that plaintiff was sexually harassed and subjected to a sexually hostile work environment, but that there was insufficient evidence to support allegations of retaliation and constructive discharge. The district court dismissed Title VII claims. The Sixth Circuit reversed. The district court did not consider and weigh all aspects of the firefighters' relationship with the department in determining that they were not "employees" under 42 U.S.C. 2000e(b); remuneration is a factor, but not decisive. The firefighters received a number of other benefits, including insurance.
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