CHICAGO (CN) — A three-judge panel of the Seventh Circuit rejected Moody Bible Institute's request to toss a pending discrimination lawsuit on Monday, finding it lacked jurisdiction to alter a lower court's ruling that the Chicago bible college found fault with.
The panel's decision stems from a Title IX sex discrimination suit that Janay Garrick, one of Moody's former instructors, brought against the college in January 2018. It had hired her in 2014 but ultimately fired her in April 2017, citing irreconcilable differences between its interpretation of Christianity and Garrick's.
The college, per appellate court filings and oral arguments the Seventh Circuit heard in December, adheres to a "complementarian" view of Christianity, which holds that women cannot serve as priests or pastors. Garrick holds egalitarian beliefs that there should be gender equality in church ministry.
"Because faculty members must 'annually confirm the doctrinal statement which includes the complementarian view of gender roles,' and because '[Garrick’s] view is different from that of Moody,' Moody could not 'give [Garrick] a contract for the next academic year,'" Moody stated in court documents.
In her lawsuit and subsequent court filings, Garrick waved away these claims of irreconcilable doctrinal disputes as pretextual, though she did add religious discrimination and Title VII gender discrimination to her list of claims in December 2018. She argued she was truly fired in retaliation for speaking out against the college's discriminatory policies toward LGBTQ+ people and women, including herself. She noted in her appellate brief that the school administration's view of her began to sour in 2015, after she and a male colleague criticized what they saw as the school's anti-LGBTQ+ culture.
She once helped a female student file a Title IX complaint against the school for excluding women from its pastoral ministry program, something she claimed also earned her the ire of the college's elders and contributed to its decision to fire her.
The college petitioned the U.S. District Court of Northern Illinois to dismiss Garrick's case, raising religious First Amendment defenses and exemptions under Title VII. Then-U.S. District Judge John Lee dismissed Garrick's claims of religious discrimination in September 2019, as well as a hostile work environment claim she added to a second amended complaint that November. But in October 2020, the Barack Obama appointee, since seated on the Seventh Circuit by Joe Biden, allowed Garrick's disparate treatment and retaliation claims from the second amended complaint to go forward.
The college appealed, hoping the appellate court would toss the case outright.
However, after considering the arguments from December, the Seventh Circuit didn't dismiss the pending suit on Moody's behalf — it dismissed Moody's appeal itself.
U.S. Circuit Court Judge Amy St. Eve, a Donald Trump appointee, cited the "collateral-order doctrine" in the 24-page majority decision to dismiss Moody's appeal. The collateral-order doctrine holds that interlocutory appeals are only appropriate when parties risk losing their rights without immediate appellate action. Finding Moody faced no such risk, St.Eve didn't bother delving into the merits of the bible college's defenses.
"Because Moody’s appeal falls outside of the collateral order doctrine’s narrow and selective class of claims subject to interlocutory review, we dismiss the appeal for lack of jurisdiction without reaching the merits of Moody’s Title VII and First Amendment defenses," St. Eve wrote.
She also opined that the school's "religious autonomy to shape and control doctrine will not be threatened" by Garrick's suit. As the case moves forward in the lower court, she urged now-presiding U.S. District Judge John Kness to "limit discovery to instances of discriminatory treatment in situations not implicated by Moody’s complementarian beliefs."
U.S. Circuit Court Judge Michael Brennan, another Donald Trump appointee, broke from the majority in a 27-page dissent. He argued that "how the parties understand and live out their faiths" was central to the case, and that as a question on religious autonomy the court should have claimed jurisdiction under the collateral-order doctrine.
Brennan wrote that "the factual background and procedural history here evidence a deep and abiding religious disagreement between Garrick and her avowed egalitarian Christianity and Moody's institutional complementarian Christianity."
"That fundamental dispute underpins Garrick’s complaints about her employment and Moody’s defense of its decisions and actions. Why she was terminated — the subject of discovery and trial — turns on this disagreement," Brennan added.
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