Plaintiff-music director, choir director and organist at defendant-Catholic Church filed Title VII and Americans with Disabilities Act claims, alleging that: (1) defendant terminated him based on his sex, marital status and disability, after his supervisor (Catholic priest) asked for his resignation following plaintiff’s same-sex marriage and told plaintiff that his marriage was against teachings of Catholic Church; and (2) prior to his termination, his supervisor allegedly made belittling and humiliating comments based on plaintiff’s disability. Dist. Ct. dismissed some of plaintiff’s hostile work environment claims, where Dist. Ct. found that ministerial exemption applied, but found that said exception did not apply to plaintiff’s disability-based, hostile environment claim, where record was silent as to religious basis for said harassment. While original panel of Ct. of Appeals reversed Dist. Ct.’s dismissal of plaintiff’s sex, sexual orientation and marital status claims, Ct. of Appeals, in reviewing case en banc, dismissed all of plaintiff’s claims, where Ct. found that ministerial exception applied to all of plaintiff’s claims, including all of his minister-on-minister, hostile environment claims, even if some of his claims did not pertain to challenge of tangible employment action, where plaintiff qualified as “minister” of Catholic Church. (Dissent filed.)
Federal 7th Circuit Court
Civil Court
Employment Discrimination