Braun v. St. Pius X Parish
827 F. Supp. 2d 1312
N.D. Okla.2011Background
- Braun, a non-Catholic (Episcopalian) fifth grade teacher at St. Pius X School in 2007-2008, was informed her contract would not be renewed in April 2008 and was 63 years old at that time.
- Defendants are St. Pius X Parish, St. Pius X School, Matthew Vereecke (principal), and Fr. Michael Knipe (pastor); Knipe is the ultimate decision maker on contract renewals.
- Vereecke recommended non-renewal to Fr. Knipe, who could veto but ultimately decided; Knipe had renewed Braun’s contract previously and overruled some of Vereecke’s recommendations.
- Five incidents in 2007-2008 are cited as bases for Braun’s non-renewal: concerns about medical opinions to a parent, failure to follow a student development plan, inadequacies with planners/communication tools, and two parent complaints from Foley and Hatfield about Braun’s teaching.
- Braun alleged age discrimination under the ADEA, religious discrimination under Title VII, and a Burk tort claim for Oklahoma public policy; defendants moved for summary judgment on all claims.
- The court granted defendants’ summary judgment on Braun’s religious discrimination claim (exemption for religious institutions) and denied Braun’s claim to the ministerial exemption; the court granted summary judgment to defendants on Braun’s age discrimination claims and related Burk tort claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Religious discrimination and Title VII exemption | Braun argues St. Pius is not a religious institution, thus not exempt. | St. Pius qualifies as a religious educational institution under the exemption; acts in religious functions. | Religious exemption applies; Braun’s claims fail. |
| Ministerial exemption applicability | Braun should fall under ministerial exemption due to role in Catholic school environment. | Braun’s duties are secular; she did not perform ministerial functions. | Ministerial exemption denied; Braun’s age claim not barred by ministerial exemption. |
| Age discrimination (Title VII and Burk tort) | Non-renewal was motivated by Braun’s age; pretext shown by inconsistent reasons and subordinate bias. | Reasons for non-renewal were legitimate, non-discriminatory, and not pretext; strong inference against discrimination. | Braun failed to show pretext; defendants entitled to summary judgment on age discrimination and Burk claims. |
Key Cases Cited
- LeBoon v. Lancaster Jewish Cmty. Ctr. Assoc., 503 F.3d 217 (3d Cir. 2007) (factors for determining religious exemption applicability)
- Corp. of Presiding Bishop v. Amos, 483 U.S. 327 (1987) (religious exemption scope for employment decisions)
- Hosanna-Tabor Evangelical Lutheran Church and School, 597 F.3d 769 (6th Cir. 2010) (ministerial exemption breadth for religious employers)
- Jones v. Okla. City Public Schools, 617 F.3d 1273 (10th Cir. 2010) (age discrimination and “but-for” causation framework)
- Kendrick v. Penske Transp. Servs., Inc., 220 F.3d 1220 (10th Cir. 2000) (pretext framework and Reeves/Unwritten policy guidance)
- EEOC v. Horizon/CMS Healthcare Corp., 220 F.3d 1184 (10th Cir. 2000) (McDonnell Douglas burden-shifting framework for discrimination)
- Adler v. Wal-Mart Stores, Inc., 144 F.3d 664 (10th Cir. 1998) (summary judgment standard in discrimination cases)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (genuine issue of material fact standard)