people are 4-H alumni. National 4-H Council, http://www.fourhcoun-cil.edu/Market/4hinfo/index. htm (accessed Mar. 21, 2001). The four "H”s stand for head, heart, hands and health. See National 4-H Council, http://www.fourhcoun-cil.edu/Market/4hinfo/4hfactsheet.htm# The 4— H Emblem and Pledge Explained (accessed Mar. 21, 2001). 2 . With regard to a related issue, we note that the district court presumed that plaintiffs had suffered an adverse employment action. We do not address the question of whether plaintiffs' claims of termination from volunteer positions based on protected conduct are equivalent to, or should be analyzed differently from, more traditional claims of termination from salaried government positions. See, e.g., Hyland v. Wonder, 972 F.2d 1129, 1135 (9th Cir.1992) (<HOLDING>). 3 . The defendants do not argue that they are
holding that loss of an arm includes loss of the hand holding that serving as a volunteer constituted a government benefit or privilege and that retaliatory actions with less momentous consequences than loss of employment such as loss of a volunteer position are equally egregious in the eyes of the constitution because a person is being punished for engaging in protected speech holding that proof of loss is not evidence of extent of loss and insured is not precluded from showing his damages were greater than shown in proof of loss holding that the degree of the loss of use of a body part is a question of fact whether the loss is for all practical intents and purposes is a question of law holding that the loss of a contract failed to constitute ascertainable loss under cutpa