neochart v2 research

cases/42usc2000e-2/f3d-918-1155-sacchi-v-ihc-health-servs.case

Source: cases/42usc2000e-2/f3d-918-1155-sacchi-v-ihc-health-servs.case

Case source: https://www.neochart.com/catalog/cases/f3d/volume_918/1155_01/index.html

Verbatim annotated passages

In general, to satisfy the test, the plaintiff must receive direct remuneration or indirect benefits that are substantial or significant and not incidentally related to advancing the purpose of the putative employer.
We conclude that Ms. Sacchi's intern relationship with the Hospital fails to satisfy the threshold-remuneration test as a matter of law for two reasons.
We also decline the invitation to conclude that all interns are protected by Title VII, the ADA, and the ADEA.
We therefore agree with the Hospital that the principles motivating the application of plain error in similar circumstances counsel that we should not exercise our discretion to reach this issue.

Exact source text

casedsl 1.2
# author: Flash2 (gemini-3.8-flash-high)
# triaged-by: Fable (2026-11-10)

case /f3d/918/1155-01
  name    Sacchi v. Ihc Health Servs., Inc.
  cite    918 F.3d 1155 (2019)
  court   United States Court of Appeals for the Tenth Circuit
  date    2019-03-26
  url     catalog/cases/f3d/volume_918/1155_01/index.html
  source  ir/caselaw/f3d_918.jsonl sha1=126d98b04dab1f775f6fcab25936f5b8895f88fd chars=15598

opinion maj : majority by Kelly @0..15598 controlling

law 42usc2000e-2 (a), (d)
  role    applied
  posture civil; Title VII sex and religious discrimination (with ADA and ADEA claims) by an unpaid hospital intern; Rule 12(b)(6) dismissal for lack of employee status affirmed (10th Cir.)
  result  claimant-lost

element employer : not-satisfied [pleaded]
  route   employee-status
  pattern unpaid-intern-claiming-certification-eligibility-and-path-to-employment-as-remuneration
  fact @2748..2855 [cuts-against] | Relevant to this appeal, Ms. Sacchi received no direct payment or other benefits for her work as an intern.
  fact @3559..3724 [supports] | The Hospital's internship program is designed to satisfy the clinical experience requirement, and the program is accredited and recognized by the Child Life Council.
  fact @8667..8821 [cuts-against] | Although an internship was required for Ms. Sacchi to sit for a professional exam, she still had to pass the exam to receive her child life certification.
  fact @8843..9051 [cuts-against] | For her to have obtained a position thereafter, she still had to find an open position, apply for that position, and then be selected over all other applicants in what Ms. Sacchi noted is a competitive field.
  rule @7260..7476 | In general, to satisfy the test, the plaintiff must receive direct remuneration or indirect benefits that are substantial or significant and not incidentally related to advancing the purpose of the putative employer.
  held @8146..8298 | We conclude that Ms. Sacchi's intern relationship with the Hospital fails to satisfy the threshold-remuneration test as a matter of law for two reasons.
  held @10169..10279 | We also decline the invitation to conclude that all interns are protected by Title VII, the ADA, and the ADEA.
  gloss Threshold-remuneration test: an unpaid worker must first show direct pay or substantial, non-incidental indirect benefits before the common-law agency test is reached. Benefits not provided by the hospital itself and contingent on later events (passing the exam, being hired) are too attenuated.
  ? basis: the court says the relationship fails "as a matter of law", but it rules on the complaint's allegations taken as true at Rule 12(b)(6) and declines any categorical rule about interns; `pleaded` (allegations insufficient) is used rather than `law`.

element training-program : not-reached
  scope   procedural
  held @15288..15483 | We therefore agree with the Hospital that the principles motivating the application of plain error in similar circumstances counsel that we should not exercise our discretion to reach this issue.
  gloss Footnote: the panel itself asked for supplemental briefing on whether 2000e-2(d) (training programs) covers this internship, then declined to reach the theory because it was never raised in the district court.