Can a volunteer who is not paid a salary or wage be considered an employee under Title VII?

Moreover, individuals who are not paid a salary or wage may still be employees under Title VII. Waisgerber v. City of L.A., 406 F. App'x 150, 152 (9th Cir. 2010). Unpaid employees, however, must make some showing of remuneration by alleging "substantial benefits" as compensation for services rendered. See id. (citing cases where volunteers' receipt of pensions, life insurance, death benefits, and disability insurance made the volunteers employees for purposes of Title VII). Remuneration need not be a salary, but benefits must be more than merely incidental to the activity performed. United States v. City of N.Y., 359 F.3d 83, 92 (2d Cir. 2004).