The Ninth Circuit recently held that a "career agent" who sells the financial products and services of a group of financial services companies is an independent contractor and, accordingly, cannot sue the companies for sex discrimination under Title VII because that statute only covers employees. See Murray v. Principal Financial Group (9th Cir. June 17, 2010). In reaching this decision, the court noted that it and "virtually every other Circuit to consider similar issues, have held that insurance agents are independent contractors and not employees for purposes of various federal employment statutes."

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