Title VII

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7^th Circuit Court of Appeals

Case Name: Janay Garrick v. Moody Bible Institute

Case No.: 21-2683

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

Focus: Title VII

Janay Garrick, a former instructor at Moody Bible Institute, alleged sex discrimination and other violations under Title VII. Garrick claimed she faced hostile treatment due to her gender and the Institute’s religious principles. Moody contended that her lawsuit was exempted by Title VII’s religious clauses and the First Amendment’s principle of church autonomy. Despite the district court partially denying Moody’s motion to dismiss, Moody pursued an appeal.

However, the Seventh Circuit dismissed the appeal citing lack of jurisdiction. The court explained that it could only review a narrow range of interlocutory orders under the collateral order doctrine, and Moody’s appeal did not fall within this scope. It found that the district court’s denial of Moody’s motion to dismiss was not definitive, did not resolve significant questions distinct from the case’s merits, and would remain reviewable upon a final judgment.

The appellate court underscored that Moody’s defense, grounded in the doctrine of church autonomy, was intertwined with the substance of Garrick’s gender discrimination claims. Moreover, it noted that Moody’s argument of suffering irreparable harm without immediate review was not persuasive, as the district court could restrict discovery to instances unrelated to Moody’s religious beliefs. Ultimately, the court determined that Garrick’s lawsuit’s progression wouldn’t endanger religious autonomy to define and oversee doctrine.

Decided 03/18/24

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