A volunteer director of a nonprofit homeowner’s association has not alleged facts that would constitute “employment” by the association and is therefore not entitled to protection under Title VII of the federal Civil Rights Act, a magistrate judge in Pennsylvania has ruled. The judge has dismissed a claim for harassment and retaliation but allowed the director to amend the complaint if she can bring herself within the definition of an employee. Darlene Fiscus was the unpaid Chair and Chief Operating Officer of the Big Bass Lake Community Association in the Pocono mountains. She brought suit without an attorney against the Association and several individual members of its Board for gender-...