341 F. Supp. 3d 642
W.D. La.2018Background
- Aguillard served as President of Louisiana College (LC) until 2014 and later became President Emeritus and tenured faculty; conflict arose with incoming President Brewer.
- Aguillard filed a workplace violence complaint alleging threats by a Calvinist group member; he alleges subsequent ostracism, confrontation by an investigator, seizure and alleged hacking of computers, hospitalization, and ongoing harassment.
- LC placed Aguillard on administrative leave, reassigned his classes, changed office locks, and ultimately terminated him effective March 31, 2016 after internal proceedings.
- Aguillard filed EEOC charges alleging disability and religious discrimination (he identifies as Southern Baptist and disputes Calvinist influence), and alleged retaliation; he obtained a Right-to-Sue letter.
- LC moved for partial summary judgment asking dismissal of Aguillard’s Title VII religious discrimination and religious retaliation claims based on Title VII exemptions for religious organizations and religious educational institutions.
- The court concluded LC is both a religious organization and a religious school under Title VII exemptions and granted partial summary judgment dismissing the religious-discrimination and religious-retaliation claims with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether LC is exempt from Title VII's prohibition on religious discrimination (42 U.S.C. §2000e-1(a) / §2000e-2(e)(2)) | Aguillard disputed applicability of religious exemptions, arguing ministerial/abstention doctrines controls and that LC is not a church or that he is not a minister | LC argued it is a private, Baptist-affiliated college whose mission, governance, curriculum, funding, and practices establish it as a religious organization and religious educational institution exempt from Title VII | Court held LC qualifies as both a religious organization and religious school; Title VII religious-discrimination claim is barred and dismissed with prejudice |
| Whether Title VII’s anti-retaliation provision applies to religious employers in this context | Aguillard contended retaliation claim is actionable under Title VII | LC argued the statutory exemption for religious organizations in §2000e-1(a) (and §2000e-2(e)(2) for schools) removes the subchapter’s reach, including the anti-retaliation provision | Court held the statutory exemptions preclude religious-retaliation claims under Title VII and dismissed the retaliation claim with prejudice |
| Whether the ministerial exception or ecclesiastical abstention preclude Aguillard’s claims | Aguillard argued ministerial/abstention doctrines demonstrate the claims are inappropriate or inapplicable as framed | LC did not rely on ministerial exception; moved on statutory exemptions instead | Court declined to decide ministerial/abstention issues (not presented by LC) and resolved the case on the statutory exemptions |
| Whether factual disputes (e.g., LC's religious character) preclude summary judgment | Aguillard claimed LC is not entitled to exemption and offered little evidence to dispute LC’s proffers | LC submitted uncontested evidence (charter, mission statements, governance by Louisiana Baptist Convention, curriculum, chapel, hiring expectations, funding mix, tax-exempt status) | Court found no genuine dispute of material fact that LC is religious under the relevant statutes and granted summary judgment |
Key Cases Cited
- Corporation of Presiding Bishop v. Amos, 483 U.S. 327 (establishes Title VII §2000e-1(a) exemption for religious organizations)
- EEOC v. Mississippi College, 626 F.2d 477 (5th Cir.) (interprets §2000e-1 to exempt religious college employment practices even if pretextual)
- Hall v. Baptist Memorial Health Care Corp., 215 F.3d 618 (6th Cir.) (applies religious school/organization exemptions to bar Title VII religious-discrimination claims)
- Killinger v. Samford University, 113 F.3d 196 (11th Cir.) (factors supporting a university’s qualification for religious-organization exemption)
- Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (recognizes ministerial exception under the Religion Clauses, but court decided this case on statutory exemptions)
- Kennedy v. St. Joseph's Ministries, Inc., 657 F.3d 189 (4th Cir.) (holds religious-retaliation claims barred by Title VII exemptions)
- Saeemodarae v. Mercy Health Servs., 456 F. Supp. 2d 1021 (N.D. Iowa) (analyzes factors for institutional religiosity and concludes Title VII exemptions bar retaliation claims)