Davis v. Baltimore Hebrew Congregation, 2013 U.S. Dist. LEXIS 169471

Davis, African-American, employed by Baltimore Hebrew Congregation (BHC) since 1998 as Associate Facilities Manager, later Facilities Manager.
Davis’s duties included maintenance, repairs, custodial work, and supervising staff; he reported to BHC’s Executive Director.
In Oct 2008, Davis lost scheduling and purchasing authority, though he remained responsible for ensuring adequate maintenance staffing and coverage.
In 2009, Davis faced performance issues including communication failures, disrespectful conduct, and failure to complete tasks; he was ultimately terminated on Oct 5, 2009 with multiple stated reasons.
Davis alleges race discrimination, claiming a plantation-like environment and a racial slur incident by a non-employee; most time-barred under Morgan for Title VII, with §1981 analysis limited to timely acts.
Davis also asserted disability discrimination and retaliation under the ADA and state wage claims; the court held in each instance that Davis failed to establish prima facie or pretext, and at-will status and handbook language undermined contract and wrongful discharge theories.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ministerial exception applicability	Davis’s role involved religious aspects; ministerial exception should bar claims.	Davis was not a minister; primary duties were secular.	Ministerial exception does not apply; claims proceed to merits.
race discrimination under §1981/Title VII	Davis claims discriminatory termination and hostile environment.	No timely prima facie case; legitimate non-discriminatory reasons shown.	No triable issue; under McDonnell Douglas, no pretext proven; summary judgment for BHC.
§1983 and §1982 claims; property and state action	Fourth Amendment/ equal protection concerns preserved.	BHC not a state actor; §1983 claim fails; §1982 requires a protected property interest which Davis lacked.	Counts II and III are resolved in Defendant’s favor.
ADA and failure to accommodate	Davis sought reasonable accommodations for back injury; qualified disability status disputed.	Accommodation requested would require additional staff; Davis could work light duty and assign tasks.	No prima facie ADA claim; summary judgment for BHC.
breach of contract and wrongful discharge	Handbook created contractual rights; wrongful discharge claim applicable.	Handbook states at-will employment and disclaims contractual intent.	No contract or wrongful discharge claim; summary judgment for BHC.

Hosanna-Tabor Evangelical Lutheran Church v. EEOC, 565 U.S. 171 (2012) (ministerial exception applies to religious employment relations)
Rayburn v. Gen. Conf. of Seventh-Day Adventists, 772 F.2d 1164 (4th Cir. 1985) (fact-specific 'primary duties' test for ministerial exception)
EEOC v. Roman Catholic Diocese of Raleigh, N.C., 213 F.3d 795 (4th Cir. 2000) (ministerial-employee analysis in religious institutions)
Shaliehsabou v. Hebrew Home of Greater Washington, Inc., 363 F.3d 299 (4th Cir. 2004) (extensive training/role recognized as ministerial for some staff)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for proving and addressing discrimination claims)
St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (1993) (pretext evidence standard after prim a facie case)
Morgan v. National Railroad Passenger Corp., 536 U.S. 101 (2002) (timing of discriminatory acts; timely acts required for liability)