Garrick v. Moody Bible Institute

Plaintiff-female teacher filed Title VII action, alleging that she was terminated from her teaching position on account of her gender. Dist. Ct. initially granted defendant-religious school's motion to dismiss based on various religious exemptions and First Amendment doctrine of church autonomy, but allowed plaintiff to file amended complaint that alleged disparate treatment in her teaching opportunities and obligations. In its termination letter to plaintiff, defendant asserted that plaintiff’s non-alignment with defendant’s religious complementarian beliefs made her poor fit for her teaching position. When defendant filed second motion to dismiss. Dist. Ct. granted part of motion, but denied part of motion addressing plaintiff’s disparate treatment claims. Ct. of Appeals, in dismissing defendant’s interlocutory appeal as being non-final, found that Dist. Ct.’s order did not otherwise qualify as appropriate category of order subject to collateral order doctrine. Specifically, Ct. of Appeals observed that church autonomy does not bar courts from adjudicating all disputes involving religious institutions, and district court orders denying church-autonomy and Title VII’s religious-exemption defenses cannot be immediately appealed, where, as here, merits of plaintiff’s disparate treatment claims, do not appear to require judicial entanglement by Dist. Ct. into religious doctrinal matters (Dissent filed.)