Sacchi v. IHC Health Servs., Inc., 918 F.3d 1155 (10th Cir. Mar. 26, 2019)

In this employment case, an intern argued that she should be treated as an employee under federal discrimination laws, even though she received no pay, because she received benefits from the internship program, including completing requirements of education program and advancing her professional certification.  Applying the “threshold remuneration” test used in other circuits, the Tenth Circuit held that the intern was not an employee, where the benefits alleged were not provided by the hospital, were different from traditional benefits, such as a pension or insurance, and were too attenuated to give rise to an employment relationship.