In Storms v. Carcieri, (D NJ, May 26, 2026), a New Jersey federal district court dismissed a suit which challenged a requirement by the Somerset County YMCA that in order to serve as a Board member, a board nominee must complete a 30-minute training course titled "Advancing Equity, Understanding Biases." Plaintiff Michael Storms refused to take the course because it violated his "deeply held religious belief that only Jesus Christ can forgive my sins." Storms, proceeding pro se, sued alleging that imposing the requirement on him violated his 1st and 14th Amendment rights, as well as Title VI and Title VII of the 1964 Civil Rights Act and the New Jersey Civil Rights Act. A number of his claims were dismissed because he had not plausibly alleged that the YMCA's conduct involved state action. The court dismissed plaintiff's Title VI claim because Title VI only bars discrimination on the basis of race, color or national origin. It does not cover religious discrimination. He also failed to show that the federal funding received by the national YMCA organization was the source of any of operations of the local entity.
Interestingly, in his complaint, Plaintiff also listed "Jesus Christ" as a plaintiff. In a footnote the court said: "The Court finds that Jesus Christ is not a proper plaintiff and proceeds in its analysis with Storms as the sole plaintiff in this matter."
