That was the question when a woman firefighter and paid administrative assistant of a nonprofit volunteer fire company filed a claim for sexual harassment and retaliation under Title VII of the federal Civil Rights Act. The fire company argued that although it had a large number of volunteer firefighters, it did not have 15 “employees” as required to meet the minimum number for coverage under the law. A federal District Court in Ohio granted the company’s motion for summary judgment to dismiss the claims. The Sixth Circuit Court of Appeals has reversed. The statute says an employee is an “individual employed by an employer,” which the Court said, “is completely circular and explains nothing...