Title VII's Religious Organization Exemption Protects Salvation Army

In Garcia v. Salvation Army, (D AZ, Sept. 12, 2016), an Arizona federal district court dismissed a Title VII religious discrimination claim brought against the Salvation Army by a former social services coordinator for the organization.  Plaintiff claimed that she was subjected to discrimination, retaliation, and hostile work environment after she stopped attending services at the Salvation Army’s Estrella Mountain Corps where she was employed.  The court held that Title VII's religious organization exemption applies to plaintiff's claim, and that the Salvation Army did not waive the defense by failing to assert it as an affirmative defense.