I just saw a squib for Evans v. Washington Center for Internships and Academic Seminars, 2008 WL 4937007 (D.D.C. Nov. 19), holding that:
Plaintiff's sexual harassment claims fail because she was not an "employee" within the meaning of the [D.C. Human Rights Act]. The DCHRA defines an employee as "any individual employed by or seeking employment from an employer." The statute defines an employer as "any person who, for compensation, employs an individual...." Plaintiff did not satisfy this definition, as she was not working for compensation, nor was she seeking a paid job. Moreover, while this issue has never been decided under the DCHRA, it has consistently been held under Title VII that an unpaid intern is not an employee.
Well, OK, the plaintiff was an intern at a chiropractor's office, but naturally that wasn't the first sort of employer that came to mind when I read the summary .... And, just to be extra precise, this case also reflects that it is not a violation of the federal Title VII to sexually harass interns in D.C. or elsewhere.