It depends on what the guy thinks.
If you are referring to the "friendzone *tm", then yes, she is.
For some people, simply being nice to a girl all but forces her to at least have sex with him, or go on a date or something; not doing so puts him in the 'friendzone', and makes the girl a 'prude', 'b***h' or similar terms.
Personally, i don't believe that the friendzone is a thing, since i do not believe that anything puts a girl in the situation where she *has to* have sex with a guy, which removes the premise.
I am also a strong believer of the possibility of men and women being "just friends", without any tension from either end; many of my good friends are female, and i don't want to have sex with them (or, at least, that is not why i am friends with them, and i am perfectly happy with that situation).
to answer the opening question: i'd say "no, and if he disagrees, be careful around him"