In Califano v. Roman Catholic Diocese of Rockville Centre, New York, (ED NY, Sept. 24, 2024), a New York federal district court refused to stay discovery in a Title VII sex discrimination suit brought by an openly gay math and English teacher at a Catholic elementary school. The court said in part:
... [A]t the motion to dismiss stage, “a [p]laintiff only has a minimal burden of alleging facts suggesting an inference of discriminatory motivation.”...
Plaintiff has plainly satisfied this standard. Here, Plaintiff never received any criticisms about his job performance. Instead, the Complaint alleges he was terminated based exclusively on his sexual preference after Defendants saw a social media post of him kissing his partner— another male. More importantly, there is direct evidence for the termination: Defendants’ own personnel alluded to his homosexuality as a reason for the termination....
... [T]he question of application of the ministerial exception is fact specific. That said, resolution on a motion to dismiss would be inappropriate....
... Plaintiff’s duties are not as intertwined with religious doctrine. He was not a rabbi, priest, or member of the clergy with formal doctrinal training. Therefore, deciding his Title VII claim would not impinge on the church autonomy doctrine and Defendants’ defense fails. And here, Defendants fail to point to demonstrate that they would have fired Plaintiff even in spite of his identifying as a homosexual male....
Although the ministerial and church autonomy doctrines appear to be inapplicable to Plaintiff’s claim, at the very least, discovery is necessary to proceed with this case--namely to discern whether the exceptions even apply to Plaintiff’s role as a Math and English teacher here.
