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Keywords

defendantequitydiscriminationpartnership

defendantequitysummary judgmentdiscriminationpartnershipsustainedappellant

Related Cases

Serapion v. Martinez, 119 F.3d 982, 74 Fair Empl.Prac.Cas. (BNA) 601, 71 Empl. Prac. Dec. P 44,887

Facts

Margarita Serapión, a certified public accountant, transitioned to law and joined the law firm Martínez, Odell, Calabria & Sierra as an associate. She became a junior partner and later a senior partner, receiving a 4% equity interest and participating in management decisions. However, she alleged that her male partners conspired to prevent her from achieving parity and ultimately dissolved the firm to exclude her from the new partnership. Serapión claimed sex discrimination under Title VII after the dissolution.

Serapión earned a distinguished reputation as a certified public accountant before deciding to switch careers. After graduating from the University of Puerto Rico Law School with honors in 1982, she joined the San Juan law firm of Colorado, Martínez, Odell, Calabria & Sierra as an associate. She left in 1983 for a stint in government service but returned in 1985. In the interim, Colorado had departed and the partnership had been reconstituted.

Issue

Is a partner in a law firm considered an employee under Title VII, and therefore entitled to its protections against sex discrimination?

Rule

Title VII protects employees from discrimination based on sex, but it does not extend its protections to individuals who are considered partners in a business, as they are not classified as employees.

Although the language we have quoted speaks of “any individual,” courts long ago concluded that Title VII is directed at, and only protects, employees and potential employees.

Analysis

The court analyzed Serapión's status by examining her role and responsibilities within the firm. It found that she had significant ownership interests, participated in management, and was liable for the firm's debts, indicating that she functioned more as a proprietor than an employee. The court concluded that her title as a partner did not equate to employee status under Title VII.

The factors relevant to ownership and remuneration provide powerful indications that the appellant should not be treated as an employee for Title VII purposes. It is undisputed that Serapión received an equity interest in the Firm upon being named a proprietary partner. Her compensation was predicated in substantial measure on the Firm's profits, and she would have been liable had the Firm sustained losses.

Conclusion

The court affirmed the lower court's ruling, holding that Serapión was not an employee under Title VII and thus not entitled to its protections.

Consequently, we affirm the lower court's entry of summary judgment in the defendants' favor.

Who won?

Defendants (former partners and new partnership) prevailed because the court determined that Serapión was not an employee under Title VII, which precluded her from claiming discrimination.

The court held that Serapión was not an employee as that term had been developed in federal jurisprudence and that she was thus ineligible for the prophylaxis of Title VII.

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