Ohio Civil Rights Comm'n v. Dayton Christian Schools, Inc.

Ohio Civil Rights Comm'n v. Dayton Christian Schools, Inc.
Supreme Court of the United States
Argued March 26–, 1986 Decided June 27, 1986
Full case name	Ohio Civil Rights Commission v. Dayton Christian Schools, Inc.
Prior history	Appeal from the United States Court of Appeals for the Sixth Circuit
Holding
That the Court of Appeals for the Sixth Circuit should not have heard this case. That the First Amendment rights of the school were not infringed by the civil rights investigation.
Court membership
Chief Justice Warren E. Burger Associate Justices William J. Brennan, Jr. · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell, Jr. · William Rehnquist John P. Stevens · Sandra Day O'Connor
Case opinions
Majority	Rehnquist (unanimous)

Ohio Civil Rights Commission v. Dayton Christian Schools, Inc., 477 U.S. 619 (1986), reversed a lower court's decision and stated that the lower court should not have heard the case until after the Ohio Civil Rights Commission had concluded their investigation. The Commission argued that the non-renewal and firing constituted unlawful sex discrimination, while the school argued that this was an ecclesiastical matter not suitable for review by civil authorities^[1].

Case Facts

Seal of the Ohio Civil Rights Commission

Linda Hoskinson was hired as an elementary school teacher at Dayton during the 1978-1979 school year. Her employment contract required following a "biblical chain of command"^[2][3] in lieu of using the state legal system and a signed statement of faith^[4]. In 1979, she became pregnant. After informing the principal, her contract to teach was not renewed as the organization believed that mothers should stay home with their pre-school aged children^[5]. When she hired an attorney, she was immediately terminated for failing to follow the internal dispute resolution protocol. She then filed a complaint with the Ohio Civil Rights Commission, claiming that the non-renewal of the contract was sexual discrimination under ORC 4112.02A ^[6], and that the termination was in violation of 4112.02I^[6]. The commission determined that there was sufficient probable cause to believe that the school had discriminated against Hoskinson based on her sex, and retaliated against her for asserting her rights. The school claimed that the First Amendment prevented the Commission from having jurisdiction, that the civil rights statutes were unconstitutionally overreaching and appealed to the US District Court seeking a permanent injunction against the state.

Title VII of the Civil Rights Act generally permits religious organizations to require membership in their religious group as a bona fide occupational qualifications^[7]. Unaddressed was one of the school's claims, that by requiring the school to hire a teacher that disobeyed the church's teachings, they would not be able to demonstrate to students that the church's doctrine was important^[8][9].

Opinion

The District Court erred in hearing this case as it was not "ripe" and that the appropriate time for an appeal would be after the Commission had brought in a finding. The Court of Appeals erred in ruling that the Commission's jurisdiction violated both the Free Exercise Clause and the Establishment Clauses of the First Amendment and the Equal Protection Clause of the Fourteenth Amendment. This permitted the Commission to resume their investigation.

See also

• List of United States Supreme Court cases, volume 477
• List of United States Supreme Court cases
• Lists of United States Supreme Court cases by volume
• List of United States Supreme Court cases by the Rehnquist Court
• Arbitration clause
• Bona fide occupational qualifications
• Dayton Christian High School

External links

• Oral arguments
• Text of Ohio Civil Rights Commission v. Dayton Christian Schools, Inc., 477 U.S. 619 (1986) is available from:  · Findlaw · Justia

• Text of Dayton Christian Schools, Inc., et al., Plaintiffs-appellants, v. Ohio Civil Rights Commission, et al., Defendants-appellees, 766 F.2d 932 is available from:  · Justia

References

1. ^ Finkelman, Paul (1999), Religion And American Law, Routledge, pp. 348–349, ISBN 0815307500 
2. ^ From the Supreme Court ruling: As a contractual condition of employment, teachers must agree to present any grievance to their immediate supervisor, and to acquiesce in the final authority of Dayton's board of directors, rather than to pursue a remedy in civil court.
3. ^ From the Appeal Court ruling: The Chain of Command is a biblically based authority structure which depends on the internal peaceful resolution of differences. The Chain of Command concept is related to the concept of giving a good report. Hoskinson's contract included the following provision:The teacher agrees to follow the Biblical pattern of Matthew 18:15-17 and Galatians 6 and always give a good report. All differences are to be resolved by utilizing Biblical principles--always presenting a united front.
4. ^ Tenenbaum, Evelyn (2000), "The application of labor relations and discrimination statutes to lay teachers at religious schools: the Establishment Clause and the pretext inquiry", Albany Law Review, http://findarticles.com/p/articles/mi_hb3243/is_2_64/ai_n28814935/, retrieved 2009-04-15 
5. ^ Dayton Christian Schools, Inc., et al., Plaintiffs-appellants, v. Ohio Civil Rights Commission, et al., Defendants-appellees (766 F.2d 932), http://cases.justia.com/us-court-of-appeals/F2/766/932/302901/, retrieved 2009-04-15 
6. ^ ^{a b} Ohio Revised Code, 4112.02 Unlawful discriminatory practices, http://codes.ohio.gov/orc/4112.02, retrieved 2009-04-15 
7. ^ Ohio Revised Code, 4112-3-15 Application for bona fide occupational qualification, http://codes.ohio.gov/oac/4112-3-15, retrieved 2009-04-15 
8. ^ Bernstein, David, Can Antidiscrimination Laws Corrupt Religious Schools?, http://www.cato.org/pub_display.php?pub_id=5398, retrieved 2009-04-15 
9. ^ Galston, William, Value Pluralism and Political Liberalism, http://www.puaf.umd.edu/IPPP/galston.htm, retrieved 2009-04-15