Definition of "employee" reconsidered; Court reinstates volunteer firefighter's gender discrimination, quid pro quo lawsuit

Marcia Bryson, a volunteer firefighter, sued the Middlefield Volunteer Fire Department, and the Fire Chief, alleging that she had been subjected to illegal gender discrimination and that the Fire Chief, Scott Anderson, had subjected her to unwanted sexual advances.  The trial judge dismissed the Title VII case, holding that since the firefighters received only nominal pay, they were not "employees" within the meaning of the Act  Bryson relied upon in filing suit.   An employe must have 15 or more "employees" or it is not subject to the terms of the Act.   The Sixth Circuit sent the case back to the lower court, requiring it to consider more than the nominal pay issue in determining whether volunteer firefighters are "employees" under Title VII.