Headed Back to a Jury
The case of Hamilton v. Southland Christian School is headed back to a jury. This comes after the Eleventh Circuit Court of Appeals remanded the case back down to the trial court after it was initially dismissed on summary judgment.
Hamilton was a teacher at the School. She got pregnant and then married the father of her child. About a month later, she met with the School's administrator and assistant administrator to tell them she was pregnant and to request maternity leave for the following year.
During the meeting, Hamilton admitted that she conceived the child before marriage, a sin in the eyes of the church. The next week Hamilton was fired. Thereafter, Hamilton filed a charge of discrimination with the EEOC under Title VII asserting that she was discriminated against because of her pregnancy.
After requesting a right-to-sue letter, Hamilton filed suit in federal court. At the close of discovery, the School moved for summary judgment which was granted and Hamilton's claims were dismissed. In dismissing her claim, the trial court held that because Hamilton had not produced evidence of a non-pregnant comparator who was treated differently, her case could not proceed.
Hamilton appealed and her case is now headed back to a jury. The appellate court ruled that Hamilton did not have to show a comparator if she could show enough non-comparison circumstantial evidence to raise a reasonable inference of intentional discrimination. Hamilton had done that by producing evidence that the School was more concerned about her pregnancy and her request for maternity leave than her admission that she had premarital sex.
So now it will be up to a jury to decide whether Hamilton was fired because of her pregnancy. It will be interesting to see how the School's defenses play out in this second round. The School raised the ministerial exception as a defense to Hamilton's claims, but that defense was not considered on appeal because it was not properly raised by the School.
Earlier this year in Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC, the Supreme Court ruled that the ministerial exception barred a teacher's claim against her church employer after she was fired for filing a lawsuit against her employer for disability discrimination. While the Supreme Court did not clarify how the exception would apply in other church related employment cases, perhaps the Hamilton case will be the first to shed some light on this issue.