View source for Ohio Civil Rights Commission v. Dayton Christian Schools, Inc.

{{Use mdy dates|date=September 2023}}
{{Infobox SCOTUS case
|Litigants=Ohio Civil Rights Comm'n v. Dayton Christian Schools, Inc.
|ArgueDate=March 26
|ArgueYear=1986
|DecideDate=June 27
|DecideYear=1986
|FullName=Ohio Civil Rights Commission v. Dayton Christian Schools, Inc.
|USVol=477
|USPage=619
|ParallelCitations=106 S. Ct. 2718; 91 [[L. Ed. 2d]] 512; 1986 [[U.S. LEXIS]] 71
|Prior=Appeal from the United States Court of Appeals for the Sixth Circuit
|Subsequent=
|Holding=The District Court erred in failing to abstain from hearing a constitutional claim while state administrative investigations were pending.
|Majority=Rehnquist
|JoinMajority=Burger, White, Powell, O'Connor
|Concurrence=Stevens
|JoinConcurrence=Brennan, Marshall, Blackmun
|LawsApplied=
}}
'''''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.<ref>{{ussc|name=Ohio Civil Rights Commission v. Dayton Christian Schools, Inc.|volume=477|page=619|year=1986}}.</ref> The commission argued that the non-renewal and firing constituted unlawful [[sexism|sex discrimination]], while the school argued that this was an ecclesiastical matter not suitable for review by civil authorities.<ref>{{Citation
| last = Finkelman
| first = Paul
| authorlink = Paul Finkelman
| title = Religion And American Law
| publisher = [[Routledge]]
| year = 1999
| pages = 348–349
| isbn = 0-8153-0750-0}}</ref>
==Case facts==
[[File:Seal of the Ohio Civil Rights Commission.svg|thumb|left|150px|[[Seal of Ohio|Seal of the Ohio Civil Rights Commission]]]]
Linda Hoskinson was hired as an elementary school teacher at [[Dayton Christian School System|Dayton Christian Schools]] during the 1978-1979 school year. Her employment contract required following a "biblical [[command hierarchy|chain of command]]"<ref>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.''</ref><ref>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.''</ref> in lieu of using the state legal system and a signed [[statement of faith]].<ref name=Tenenbaum>{{Citation
| last = Tenenbaum
| first = Evelyn
| title = The application of labor relations and discrimination statutes to lay teachers at religious schools: the Establishment Clause and the pretext inquiry
| url= http://findarticles.com/p/articles/mi_hb3243/is_2_64/ai_n28814935/
| accessdate = 2009-04-15
| work=Albany Law Review
| year=2000}}</ref> In 1979, Hoskinson became pregnant. After informing the principal, her contract to teach was not renewed as organizational leaders believed that mothers should stay home with their pre-school-aged children.<ref name=appeal>{{Citation
| title = Dayton Christian Schools, Inc., et al., Plaintiffs-appellants, v. Ohio Civil Rights Commission, et al., Defendants-appellees (766 F.2d 932)
| url=http://cases.justia.com/us-court-of-appeals/F2/766/932/302901/
| accessdate = 2009-04-15 }}</ref><ref>{{cite web|url=https://www.latimes.com/archives/la-xpm-1985-11-13-mn-5195-story.html|title= Court to Decide if Job Bias Laws Apply to Church Schools|author=Philip Hager|work=[[Los Angeles Times]]|date=November 13, 1985|access-date=August 10, 2015}}</ref> When Hoskinson 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,<ref name=ORC>{{Citation
| last = Ohio Revised Code
| title = 4112.02 Unlawful discriminatory practices
| url=http://codes.ohio.gov/orc/4112.02
| accessdate = 2009-04-15 }}</ref> and that the termination was in violation of 4112.02I.<ref name=ORC/> 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 to the United States Constitution|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 of 1964#Title VII|Civil Rights Act]] generally permits religious organizations to require membership in their religious group as a [[bona fide occupational qualifications]].<ref name=bfoqapp>{{Citation
| last = Ohio Revised Code
| title = 4112-3-15 Application for bona fide occupational qualification
| url=http://codes.ohio.gov/oac/4112-3-15
| accessdate = 2009-04-15 }}</ref> 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.<ref name=cato>{{Citation
| last = Bernstein
| first = David
| title = Can Antidiscrimination Laws Corrupt Religious Schools?
| url= http://www.cato.org/pub_display.php?pub_id=5398
| accessdate = 2009-04-15 }}</ref><ref name=galston>{{Citation
|last         = Galston
|first        = William
|title        = Value Pluralism and Political Liberalism
|url          = http://www.puaf.umd.edu/IPPP/galston.htm
|accessdate   = 2009-04-15
|archive-url  = https://web.archive.org/web/20090130120444/http://www.puaf.umd.edu/IPPP/galston.htm
|archive-date = 2009-01-30
|url-status     = dead
}}</ref>
==Opinion==
[[William Rehnquist|Justice Rehnquist]], writing for the majority of the court, found that the District Court erred in hearing the request for an injunction as a federal court should [[abstention doctrine|abstain]] until 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 of the First Amendment|Free Exercise]] and [[Establishment Clause of the First Amendment|Establishment]] clauses of the First Amendment and the [[Equal Protection Clause]] of the [[Fourteenth Amendment to the United States Constitution|Fourteenth Amendment]], as instead they should have invoked federal abstention doctrine.
==See also==
* ''[[Geduldig v. Aiello]]'' (1974)
* ''[[Hosanna-Tabor Evangelical Lutheran Church & School v. Equal Employment Opportunity Commission|Hosannna-Tabor Lutheran Church & School v. EEOC]]'' (2012)
* [[List of United States Supreme Court cases, volume 477]]
==References==
{{Reflist}}
==External links==
* {{caselaw source
| case=''Ohio Civil Rights Commission v. Dayton Christian Schools, Inc.'', {{ussc|477|619|1986|el=no}}
| courtlistener =https://www.courtlistener.com/opinion/111732/ohio-civil-rights-commn-v-dayton-christian-schools-inc/
| findlaw = https://caselaw.findlaw.com/us-supreme-court/477/619.html
| googlescholar = https://scholar.google.com/scholar_case?case=3453051502189687339
| justia =https://supreme.justia.com/cases/federal/us/477/619/case.html
| loc =http://cdn.loc.gov/service/ll/usrep/usrep477/usrep477619/usrep477619.pdf
| oyez =https://www.oyez.org/cases/1985/85-488
}}
* {{caselaw source
|case=''Dayton Christian Schools, Inc., et al., Plaintiffs-appellants, v. Ohio Civil Rights Commission, et al., Defendants-appellees'', 766 F.2d 932
|other_source1=Justia
|other_url1=http://cases.justia.com/us-court-of-appeals/F2/766/932/}}
[[Category:United States Supreme Court cases]]
[[Category:Establishment Clause case law]]
[[Category:United States free exercise of religion case law]]
[[Category:1986 in United States case law]]
[[Category:1986 in education]]
[[Category:United States Supreme Court cases of the Burger Court]]
[[Category:Education in Montgomery County, Ohio]]
[[Category:Private schools in Ohio]]
[[Category:Legal issues in pregnancy]]