Ohio Civil Rights Commission v. Dayton Christian Schools, Inc.

Ohio Civil Rights Commission v. Dayton Christian Schools, Inc., 477 U.S. 619 (1986), reversed a lower court's decision and stated that the lower court should not have heard the case until after the Ohio Civil Rights Commission had concluded their investigation.[1] The Commission argued that the non-renewal and firing constituted unlawful sex discrimination, while the school argued that this was an ecclesiastical matter not suitable for review by civil authorities.[2]

Ohio Civil Rights Comm'n v. Dayton Christian Schools, Inc.
Argued March 26, 1986
Decided June 27, 1986
Full case nameOhio Civil Rights Commission v. Dayton Christian Schools, Inc.
Citations477 U.S. 619 (more)
106 S. Ct. 2718; 91 L. Ed. 2d 512; 1986 U.S. LEXIS 71
Case history
PriorAppeal from the United States Court of Appeals for the Sixth Circuit
Holding
The District Court erred in failing to abstain from hearing a constitutional claim while state administrative investigations were pending.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell Jr. · William Rehnquist
John P. Stevens · Sandra Day O'Connor
Case opinions
MajorityRehnquist, joined by Burger, White, Powell, O'Connor
ConcurrenceStevens, joined by Brennan, Marshall, Blackmun

Case Facts
Seal of the Ohio Civil Rights Commission

Linda Hoskinson was hired as an elementary school teacher at Dayton Christian Schools during the 1978-1979 school year. Her employment contract required following a "biblical chain of command"[3][4] in lieu of using the state legal system and a signed statement of faith.[5] In 1979, she became pregnant. After informing the principal, her contract to teach was not renewed as the organization believed that mothers should stay home with their pre-school aged children.[6][7] When she hired an attorney, she was immediately terminated for failing to follow the internal dispute resolution protocol. She then filed a complaint with the Ohio Civil Rights Commission, claiming that the non-renewal of the contract was sexual discrimination under ORC 4112.02A,[8] and that the termination was in violation of 4112.02I.[8] The commission determined that there was sufficient probable cause to believe that the school had discriminated against Hoskinson based on her sex, and retaliated against her for asserting her rights. The school claimed that the First Amendment prevented the Commission from having jurisdiction, that the civil rights statutes were unconstitutionally overreaching and appealed to the US District Court seeking a permanent injunction against the state.

Title VII of the Civil Rights Act generally permits religious organizations to require membership in their religious group as a bona fide occupational qualifications.[9] Unaddressed was one of the school's claims, that by requiring the school to hire a teacher that disobeyed the church's teachings, they would not be able to demonstrate to students that the church's doctrine was important.[10][11]

Opinion

Justice Rehnquist, writing for the majority of the Court, found that the District Court erred in hearing the request for an injunction as a federal court should abstain until after the Commission had brought in a finding. The Court of Appeals erred in ruling that the Commission's jurisdiction violated both the Free Exercise and Establishment Clauses of the First Amendment and the Equal Protection Clause of the Fourteenth Amendment, as instead they should have invoked federal abstention doctrine.

See also

References
  1. Ohio Civil Rights Commission v. Dayton Christian Schools, Inc., 477 U.S. 619 (1986).
  2. Finkelman, Paul (1999), Religion And American Law, Routledge, pp. 348–349, ISBN 0-8153-0750-0
  3. From the Supreme Court ruling: As a contractual condition of employment, teachers must agree to present any grievance to their immediate supervisor, and to acquiesce in the final authority of Dayton's board of directors, rather than to pursue a remedy in civil court.
  4. From the Appeal Court ruling: The Chain of Command is a biblically based authority structure which depends on the internal peaceful resolution of differences. The Chain of Command concept is related to the concept of giving a good report. Hoskinson's contract included the following provision:The teacher agrees to follow the Biblical pattern of Matthew 18:15-17 and Galatians 6 and always give a good report. All differences are to be resolved by utilizing Biblical principles--always presenting a united front.
  5. Tenenbaum, Evelyn (2000), "The application of labor relations and discrimination statutes to lay teachers at religious schools: the Establishment Clause and the pretext inquiry", Albany Law Review, retrieved 2009-04-15
  6. Dayton Christian Schools, Inc., et al., Plaintiffs-appellants, v. Ohio Civil Rights Commission, et al., Defendants-appellees (766 F.2d 932), retrieved 2009-04-15
  7. Philip Hager (November 13, 1985). "Court to Decide if Job Bias Laws Apply to Church Schools". Los Angeles Times. Retrieved August 10, 2015.
  8. Ohio Revised Code, 4112.02 Unlawful discriminatory practices, retrieved 2009-04-15
  9. Ohio Revised Code, 4112-3-15 Application for bona fide occupational qualification, retrieved 2009-04-15
  10. Bernstein, David, Can Antidiscrimination Laws Corrupt Religious Schools?, retrieved 2009-04-15
  11. Galston, William, Value Pluralism and Political Liberalism, archived from the original on 2009-01-30, retrieved 2009-04-15
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