Title VII Religious Discrimination

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7^th Circuit Court of Appeals

Case Name: John Kluge v. Brownsburg Community School Corp.

Case No.: 21-2475

Officials: Rovner, Brennan, and St. Eve, Circuit Judges.

Focus: Title VII Religious Discrimination

Kluge brought a Title VII religious discrimination and retaliation suit against Brownsburg Community School Corporation (“Brownsburg”) after he was terminated from his employment as a teacher for refusing to follow the school’s guidelines for addressing students. Brownsburg requires its high school teachers to call all students by the names registered in the school’s official student database, and Kluge objected on religious grounds to using the first names of transgender students to the extent that he deemed those names not consistent with their sex recorded at birth. After Brownsburg initially accommodated Kluge’s request to call all students by their last names only, the school withdrew the accommodation when it became apparent that the practice was harming students and negatively impacting the learning environment for transgender students, other students both in Kluge’s classes and in the school generally, as well as the faculty. The district court granted summary judgment in favor of the school after concluding that the evidence showed that the school was unable to accommodate Kluge’s religious beliefs and practices without imposing an undue hardship on the school’s conduct of its business of educating all students that entered its doors. The district court also granted summary judgment in favor of Brownsburg on Kluge’s retaliation claim.

The undisputed evidence demonstrates that Kluge’s accommodation harmed students and disrupted the learning environment, according to the Seventh Circuit. Because no reasonable jury could conclude that harm to students and disruption to the learning environment are de minimis harms to a school’s conduct of its business.

Affirmed

Decided 04/07/23

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