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Unpaid intern not an 'employee' protected by anti-bias laws

April 02, 2019 / Jennifer Carsen

An unpaid hospital intern whose internship was terminated early was unable to establish she was an "employee" protected by Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), and the Age Discrimination in Employment Act (ADEA), the 10th U.S. Circuit Court of Appeals has ruled (Sacchi v. IHC Health Services, Inc., No. 18-4027 (10th Cir. Mar. 26, 2019)). The intern received no payment or benefits, but argued she was an employee because internship would allow her to satisfy a requirement relating to her professional certification and would help provide her a pathway to employment.