Minister-Social Worker's Claim Under Title VII Survives Motion To Dismiss

In Moore v. Metropolitan Human Service District, 2010 U.S. Dist. LEXIS 34808 (ED LA, April 7, 2010), a Louisiana federal district court held that an ordained minister employed as a social worker at a state agency that provides services to individuals with addictive disorders stated a plausible religious discrimination claim under Title VII of the 1964 Civil Rights Act. Plaintiff Beulah Moore answered religious questions posed to her by patients. Her employer gave her an ultimatum to stop speaking about God at work, or else resign. The court held:

The Court finds that Metropolitan's argument that its conduct was appropriate because it prohibited Bible-based study at a state facility misses the point. Moore alleges that Metropolitan said she could not mention God at work.... If Moore's allegation is true-and the Court must assume that it is at this stage of the proceedings -a reasonable inference to draw is that Metropolitan prohibited Moore from mentioning God even when she was not speaking with Metropolitan clients. Such an unconditional prohibition could run afoul of Metropolitan's duty to reasonably accommodate Moore's religious beliefs. Moore's direct religious discrimination claim therefore survives Metropolitan's motion to dismiss.