John Doe v. The Salvation Army in the United States, 685 F.3d 564

Doe sued the Salvation Army and Columbus ARC for employment discrimination under § 504 of the Rehabilitation Act.
The district court granted summary judgment to Salvation Army on safety and disability theories and on lack of federal funds to Columbus ARC.
Doe appealed, challenging the district court’s basis for dismissal and the program-availability issue under § 504.
The Salvation Army is a New York corporation; some local units receive federal funds, but Columbus ARC does not.
The central issue is whether the Salvation Army, as a corporation, is ‘principally engaged’ in providing social services so that the whole organization falls within § 504.
The Sixth Circuit had previously held that an entity can be within § 504 if the organization as a whole is principally engaged in the designated activities and receives federal assistance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether religious organizations are exempt from § 504 reach.	Doe contends no per se religious exemption exists.	Salvation Army argues a broad exemption applies.	Not dispositive; court analyzes scope and history.
Whether the Salvation Army is principally engaged in social services.	Doe argues the Army’s activities show social services are primary.	Salvation Army argues its religious mission dominates.	Genuine factual issue remains; summary judgment inappropriate.

Grove City Coll. v. Bell, 465 U.S. 555 (1984) (established program- or activity-wide coverage before Restoration Act)
Consol. Rail Corp. v. Da rrone, 465 U.S. 624 (1984) (broadly construed program-wide coverage under § 504)
Hamdi ex rel. Hamdi v. Napolitano, 620 F.3d 615 (6th Cir. 2010) (statutory interpretation de novo)
E.E.O.C. v. Hosanna-Tabor Evangelical Lutheran Church & School, 597 F.3d 769 (6th Cir. 2010) (religious exemption considerations acknowledged (cited as context))
Horner v. Ky. High Sch. Athletic Ass'n, 43 F.3d 265 (6th Cir. 1994) (legislative history informs scope of Restoration Act)