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6th Circuit tosses Black minister's hostile environment case against church

3 minute read

REUTERS/Andrew Kelly

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(Reuters) - A federal appeals court on Monday upheld the dismissal of a hostile work environment lawsuit by a Black minister against an Ohio church and held that the 1st Amendment's religious protections bar courts from considering some of her claims.

A three-judge panel of the 6th U.S. Circuit Court of Appeals in Cincinnati agreed that Rev. Waltrina Middleton failed to plausibly allege that she endured an anti-Black hostile work environment while employed at United Church of Christ.

The church's attorney, Amy Kullik of Mansour Gavin, in a statement said the court "relied on well-settled law to affirm the decision of the district court to dismiss the case."

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Middleton's lawyer, Matt Hurm of Hurm Law Firm, did not respond to requests for comment.

In a 2019 lawsuit, Middleton claimed she faced a racist hostile work environment while working at the Cleveland-based church in violation of Title VII of the Civil Rights Act of 1964.

Middleton said a supervisor said that her being "a sassy, young, African American woman" was a problem and asked her to get along with racist people because they gave the church money.

She also claimed the church only considered white candidates to be her supervisor and that, before she was fired, she was demoted and replaced by a white woman.

Middleton did not dispute that she was barred from pursuing a direct challenge to her firing under the so-called ministerial exception, which shields religious organizations from discrimination lawsuits brought by ministerial employees.

But she contended a court could still consider a church's tangible employment actions against a minister, such as a termination or demotion, to support a broader claim of a hostile work environment.

But U.S. Circuit Judge Danny Boggs, an appointee of former President Ronald Reagan, said courts cannot examine those actions.

"This is precisely the kind of state inquiry into church employment decisions that the First Amendment forbids," Boggs wrote.

He said the court did not need to wade into a split among federal appellate courts on whether the ministerial exception also categorically bars a minister’s hostile work environment claims, as Middleton's complaint lacked sufficient allegations.

Boggs was joined in his decision to toss the case by U.S. Circuit Judge Joan Larsen, an appointee of former President Donald Trump, and U.S. Circuit Judge Karen Nelson Moore, an appointee of former President Bill Clinton.

But Moore said the majority should have just dismissed the case because of a lack of sufficient allegations and avoided ruling on the "unnecessary" ministerial exception aspect of the appeal.

The case is Middleton v. United Church of Christ Board, 6th U.S. Circuit Court of Appeals, No. 20-4141.

For Middleton: Matt Hurm of Hurm Law Firm

For United Church of Christ: Amy Kullik of Mansour Gavin

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Nate Raymond reports on the federal judiciary and litigation. He can be reached at nate.raymond@thomsonreuters.com.

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