source omitted). Consequently, these circuits have applied a test under Title VII that finds a place for the notion that the “economic realities” of the workplace should play a significant part in determining whether someone is an “employee” for purposes of Title VII. Id; e.g., Diggs v. Harris Hospital-Methodist, 847 F.2d 270, 272 (5th Cir.1988); Garrett v. Phillips Mills, Inc., 721 F.2d 979, 981 (4th Cir.1983); Spirides v. Reinhardt, 613 F.2d 826, 831 (D.C.Cir.1979). Most circuits, however, have not adopted the “pure” economic realities test, an expansive standard used under the Fair Labor Standards Act. This test deems persons employees if, as a matter of economic reality, they depend upon the business they serve. E.E.O.C. v. Dowd & Dowd, Ltd., 736 F.2d 1177, 1178 (7th Cir.1984) (<HOLDING>). Rather, most circuits apply a test first set
recognizing the economic realities test for title vii holding that relief granted under title vii is against the employer not individual employees whose actions constituted a violation of title vii emphasis in original holding that a title vii plaintiff could not hold coworkers liable in their individual capacities under title vii recognizing title vii does not provide the exclusive remedy for all employment discrimination claims even if the title vii and section 1983 claim factually overlap holding claims based on title vii subject to arbitration