Commission on Human Rights and Opportunities v. Echo Hose Ambulance

Summary

The court held that the remuneration test, rather than the common-law right-to-control test, governs whether an unpaid volunteer is an employee under CFEPA. Because Sarah alleged neither wages nor nonincidental benefits and did not claim that she could satisfy the remuneration threshold, the court affirmed dismissal of the complaint. The court reasoned that CFEPA should generally be interpreted consistently with federal antidiscrimination law and that the legislature's treatment of unpaid interns reinforced this result.