Court: District Court, W.D. Louisiana; September 19, 2018; Federal District Court
Joe W. Aguillard filed a lawsuit against Louisiana College (LC) alleging discrimination based on his religious beliefs and retaliation for engaging in protected activities under Title VII of the Civil Rights Act of 1964. Aguillard claims that LC discriminated against him after he filed a workplace violence complaint regarding Kyle Johnson, who he alleges had threatened his life and was a proponent of the Calvinist beliefs that Aguillard opposes. Following this complaint, Aguillard contends that LC's President, Dr. Richard B. Brewer, attempted to coerce him into resigning, isolated him from faculty activities, and failed to communicate regarding his duties.
On September 28, 2015, Aguillard alleges that Don Benton Connor, an investigator for Brewer, threatened him, demanded his resignation due to "religious issues," and unlawfully seized two computers containing confidential information, resulting in Aguillard's hospitalization for acute PTSD and heart-related concerns. Aguillard asserts that following his hospital discharge, Brewer continued to monitor him and retaliated against Dr. Carmacia Smith-Ross for refusing to provide false testimony about Aguillard's work performance and health status. LC filed a Motion for Partial Summary Judgment to dismiss Aguillard's claims of religious discrimination and retaliation, which the court granted.
On January 22, 2016, Dr. Cheryl Clark informed Aguillard that his employment at LC was "at will," allowing LC to terminate him without cause. Following this, on January 29, 2016, Brewer placed Aguillard on administrative leave, removing his responsibilities as "President Emeritus" and reassigning his classes. Aguillard filed a whistleblower complaint on February 9, 2016, alleging retaliation by Brewer for his opposition to unlawful discrimination. On February 17, 2016, LC changed the locks on Aguillard's office, denying him access to his property. The Faculty Affairs Advisory Committee held a hearing on February 23, 2016, and recommended his dismissal. Brewer officially terminated Aguillard's employment on March 16, 2016, effective March 31, 2016, after which Aguillard appealed unsuccessfully to the Executive Committee and the Board of Trustees. LC ceased all compensation under the Employment Agreement on the termination date. Aguillard filed discrimination charges with the EEOC and the Louisiana Commission on Human Rights on April 1, 2016, alleging discrimination based on disability, religion, and retaliation for opposing illegal practices. He claimed that his non-Calvinistic beliefs contributed to his termination. On July 8, 2016, Aguillard filed an additional charge detailing his conflict with Brewer's Calvinistic views. The EEOC issued a "Right to Sue" letter on September 28, 2017. Aguillard contends that LC's reasons for his termination were a pretext for retaliation against his religious beliefs, disability, age, and opposition to discrimination. In response, LC has moved for partial summary judgment, arguing that it is exempt from Title VII's provisions due to its status as a religious educational institution. The court is prepared to rule on this motion, which is fully briefed. Under Federal Rule of Civil Procedure 56(a), summary judgment is warranted if there are no genuine disputes regarding material facts, with the moving party responsible for demonstrating this absence.
A party claiming that a fact is undisputed must provide specific citations from the record to support this assertion. A "material" fact is one whose existence or nonexistence could influence the lawsuit's outcome, as defined in *Anderson v. Liberty Lobby, Inc.*, 477 U.S. 242 (1986). A fact dispute is "genuine" if reasonable evidence exists that could allow a verdict for the nonmoving party. If the moving party meets its initial burden, the burden shifts to the nonmoving party to demonstrate a genuine issue of material fact exists for trial. The court must accept the nonmovant's evidence as credible and draw reasonable inferences in their favor, though summary judgment cannot be defeated by mere conclusory claims or minimal evidence, as noted in *Turner v. Baylor Richardson Med. Ctr.*, 476 F.3d 337 (5th Cir. 2007).
Aguillard alleges religious discrimination and retaliation under Title VII of the Civil Rights Act. 42 U.S.C. § 2000e-2(a)(1) prohibits employment discrimination based on race, color, religion, sex, or national origin, while § 2000e-3(a) prohibits retaliation against employees who oppose discriminatory practices. However, there are exemptions for religious organizations and educational institutions under 42 U.S.C. § 2000e-1(a), which excludes these entities from certain employment laws concerning individuals of a specific religion. Additionally, § 2000e-2(e)(2) allows educational institutions to hire individuals of a particular religion if they are substantially associated with that religion or promote its teachings.
LC seeks partial summary judgment, arguing that these exemptions apply to Aguillard's claims. Aguillard contends that the exemptions should be analyzed through the lens of the ministerial exception and ecclesiastical abstention doctrine. The court concludes that the exemptions do apply, thereby barring Aguillard's claims of religious discrimination and retaliation.
In Corporation of Presiding Bishop of Church of Jesus Christ of Latter-Day Saints v. Amos, the Supreme Court established that Section 702 of the Civil Rights Act of 1964 exempts religious organizations from Title VII’s employment discrimination prohibitions based on religion. The Court affirmed that Congress intended this exemption to alleviate governmental interference with religious organizations' missions. The Fifth Circuit's decision in EEOC v. Mississippi College reinforced this by stating that Section 702 protects religious educational institutions from Title VII in cases of employment practices that discriminate on the basis of religion, regardless of whether such discrimination serves as a pretext for other forms of discrimination. Similarly, the Sixth Circuit in Hall v. Baptist Memorial Health Care Corp. upheld that a religious educational institution associated with the Baptist church was entitled to Title VII exemption from claims of religious discrimination. The court emphasized the constitutional rights of religious organizations to make employment decisions based on religious beliefs, concluding that the institution's actions, including termination of employees whose beliefs conflicted with its religious principles, fell under the exemptions provided by the statute. The court affirmed that the institution qualified for the exemption as it was substantially supported and managed by a religious corporation. The Eleventh Circuit has also aligned with this interpretation.
In Killinger v. Samford University, the Eleventh Circuit upheld the summary judgment dismissal of a Title VII religious discrimination claim, determining that a Baptist university's partial dismissal of a faculty member was justified under Title VII exemptions due to differing religious beliefs with the dean. The court affirmed that these exemptions also apply to retaliation claims, as illustrated in Saeemodarae v. Mercy Health Services, where the court ruled that a religious retaliation claim could not be sustained under Title VII exemptions. The court in Lown v. Salvation Army also dismissed a Title VII retaliation claim, citing Section 702, which exempts religious institutions from this subchapter, including the anti-retaliation provision. The exemption's plain language indicates that it encompasses retaliation claims, reinforcing the constitutional rights of religious organizations to make employment decisions based on religious motivations. Additionally, the Fourth Circuit in Kennedy v. St. Joseph's Ministries found similar results, barring religious retaliation claims under Title VII exemptions. While Aguillard argues against the ministerial exception and ecclesiastical abstention doctrine, these legal principles maintain that civil courts should not interfere in religious employment matters. The Supreme Court has recognized a ministerial exception that prevents government interference in a religious group's decisions regarding its ministers, supporting the notion that religious organizations have discretion in employment based on religious criteria.
The Court is considering whether LC is entitled to partial summary judgment regarding Aguillard's claims of religious discrimination and retaliation under Title VII exemptions 2000e-1(a) and 2000e-2(e)(2). The question of whether Aguillard's claims are barred by the ministerial exception or the ecclesiastical abstention doctrine is not at issue. The determination hinges on whether LC qualifies as a religious organization or educational institution under these exemptions, with no specific guidance from the Fifth Circuit. Other courts have analyzed various factors to assess qualification.
Key considerations include the religious nature of the organization, such as its support and control by a religious entity, its mission alignment with a religious denomination, and its founding by sectarian groups. The "atmosphere" of the institution is also crucial, evaluated through factors like religious symbolism, recruitment practices, orientation information about its religious mission, required religious studies, and observance of religious ceremonies. The Saeemodarae court referenced Hall v. Baptist Memorial Health Care Corp., which emphasized the specificity of the "religious school" exemption compared to the "religious organization" exemption, and noted that secular training does not negate a religious identity.
Additionally, in Killinger v. Samford University, factors such as the institution's founding by a religious organization, trustee affiliations, and financial ties to religious entities were critical for qualifying under the "religious organization" exemption. Thus, the Court will evaluate LC's status against these established criteria to determine its eligibility for the exemptions.
The school is affiliated with the Association of Baptist Colleges and Schools and mandates that all faculty subscribe to the 1963 Baptist Statement of Faith and Message, as reflected in faculty contracts and the handbook. Its charter emphasizes the promotion of the Christian religion, requiring all students to attend chapel, with the IRS granting the institution religious exemptions. The court case referenced does not imply that these elements are necessary for an institution to claim such exemptions.
Louisiana College (LC) is characterized as a private, non-profit educational institution with no affiliation to the State of Louisiana or reliance on public funding. Central to LC's identity is the Christian faith, fostering student learning and growth in the Baptist tradition. Established in 1906 as a non-profit with the goal of promoting Baptist education, LC emphasizes a community of learning grounded in Christian perspectives.
Governance is maintained by a Board of Trustees appointed by the Louisiana Baptist Convention. The Faculty Handbook outlines LC's commitment to Christian teachings and values, aiming to provide a liberal arts education that honors Jesus Christ and the Holy Scriptures. Prospective students are informed about the religious mission of the institution, reinforced during orientation.
LC's Central Core Curriculum aims to instill a biblical worldview among students, enabling them to understand the Bible's content and Christian doctrines. Chapel services, including livestream options, are integral to the educational experience. Additionally, LC recruits faculty and staff who are committed Christians, actively participating in local churches and aligning with the institution's doctrinal statement, promoting high Christian values throughout the community.
LC derives 81.2% of its annual budget from student registration fees, with 10.8% from the Cooperative Program/Louisiana Baptist Convention. As a nonprofit religious corporation, LC has been consistently exempt from federal income taxation under 26 U.S.C. 501(c)(3). The court in Louisiana College v. Sebelius recognized LC as a private, coeducational institution dedicated to Baptist education, employing faculty and staff who adhere to Christian principles and lifestyles. LC qualifies as a "religious organization" under 42 U.S.C. 2000e-1(a) and a "religious school" under 42 U.S.C. 2000e-2(e)(2), which exempts it from Title VII's prohibitions against religious discrimination and retaliation. Aguillard contested these exemptions but failed to present evidence to dispute LC's status. The court granted LC's Motion for Partial Summary Judgment and dismissed Aguillard's claims with prejudice.
