Trinity Christian Sch. v. Comm'n on Human Rights
189 A.3d 79
| Conn. | 2018Background
- Trinity Christian School (a religious school) was sued at the Commission on Human Rights and Opportunities by a former female employee alleging sex, marital status, and pregnancy discrimination under Conn. law and Title VII.
- Trinity moved to dismiss at the commission, asserting the ministerial exception and later that Conn. Gen. Stat. § 52-571b(d) immunized religious institutions from such employment-discrimination suits.
- The commission denied Trinity’s motions; Trinity appealed the denial to Superior Court as an interlocutory administrative appeal under Conn. Gen. Stat. § 4-183(b).
- The Superior Court dismissed Trinity’s administrative appeal for lack of subject-matter jurisdiction, holding § 52-571b(d) is a rule of construction (not a grant of immunity) and thus the denial was not immediately appealable.
- Trinity appealed to the Connecticut Supreme Court, which affirmed: § 52-571b(d) does not confer immunity from suit and the ministerial exception—per Hosanna-Tabor—operates as an affirmative defense rather than a jurisdictional bar.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 52-571b(d) grants religious institutions immunity from employment-discrimination suits | § 52-571b(d) immunizes religious institutions from such suits, allowing immediate interlocutory appeal | § 52-571b(d) is a rule of construction, not an immunity grant; no immediate appeal | Court held § 52-571b(d) is a rule of construction, not an immunity grant; no immediate appeal |
| Whether commission denial of motion to dismiss is immediately appealable under § 4-183(b) | Denial is immediately appealable because Trinity claims immunity from suit | Denial is interlocutory because Trinity has only an affirmative defense, not immunity | Court held denial was not immediately appealable; appeal dismissed for lack of jurisdiction |
| Whether ministerial exception functions as jurisdictional bar or affirmative defense post-Hosanna-Tabor | Trinity (implicitly) argued ministerial protection should preclude agency jurisdiction | Commission: Hosanna-Tabor treats ministerial exception as an affirmative defense, not jurisdictional | Court followed Hosanna-Tabor: ministerial exception is an affirmative defense, not a jurisdictional bar |
| Whether legislative history supports interpreting § 52-571b(d) as creating immunity | Legislative history purportedly shows intent to shield religious employment decisions from state burden | Legislative history shows focus on restoring strict scrutiny for religious exercise and distinguishing beliefs from practices; no clear grant of immunity | Court rejected plaintiff’s reliance on legislative history; statute text and comparison to explicit immunity statutes show no immunity grant |
Key Cases Cited
- Dayner v. Archdiocese of Hartford, 301 Conn. 759 (Conn. 2011) (discussing ministerial-exception immunity in Connecticut prior to Hosanna-Tabor)
- Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (U.S. 2012) (holds ministerial exception is an affirmative defense, not a jurisdictional bar)
- Employment Div., Dep’t of Human Resources v. Smith, 494 U.S. 872 (U.S. 1990) (limits application of strict scrutiny to generally applicable laws; prompted state RFRA-style statutes)
- Rweyemamu v. Comm’n on Human Rights & Opportunities, 98 Conn. App. 646 (Conn. App. 2006) (interprets § 52-571b as preserving distinction between religious practices and beliefs and not subjecting beliefs to strict scrutiny)