Ohio Civil Rights Commission v. Dayton Christian Public Schools, Inc.

PETITIONER: Ohio Civil Rights Commission, et al.
RESPONDENT: Dayton Christian Schools, Inc., et al.
LOCATION: Dayton Christian School

DOCKET NO.: 85-488
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 477 US 619 (1986)
ARGUED: Mar 26, 1986
DECIDED: Jun 27, 1986

ADVOCATES:
Kathleen McManus - for appellants
Kathleen Mc Manus - on behalf of the appellants
William B. Ball - on behalf of the appellees
William Bentley Ball - for appellees

Facts of the case

Dayton Christian Schools, Inc. (Dayton) is a private, non-profit corporation formed by two churches for the purposes of providing private education at the primary and secondary levels. The corporate charter includes a section that requires employees to subscribe to a particular set of religious beliefs, including a resolution of disputes through the “Biblical chain of command,” which means that all disputes must be handled internally, without redress in civil court. p>

Linda Hoskinson was a teacher at Dayton during the 1978-1979 school year. She agreed to the requirement of the corporate charter, including the Biblical chain of command. In January 1979, Hoskinson informed her principal that she was pregnant and was told that her employment contract would not be renewed because of the organization’s belief that mothers should stay home with their young children. Rather than appealing the decision internally, Hoskinson contacted a lawyer and threatened to sue based on state and federal sex discrimination laws if her employment contract was not renewed. Hoskinson was suspended and then fired for going outside of the internal dispute resolution system.

Hoskinson filed a complaint with the Ohio Civil Rights Commission, which filed an order that required Dayton to reinstate Hoskinson with backpay. When Dayton did not respond, the Commission filed suit. Dayton responded by arguing that that the First Amendment prevented the Commission from having jurisdiction over the exercise of religious beliefs. While the administrative proceedings were pending, Dayton sued the commission in district court and sought an injunction against the state proceedings because they violated the First Amendment. The Commission filed a motion to dismiss and argued that federal abstention doctrines meant that the district court should let the administrative proceedings run their course. The district court refused the issue the injunction without addressing the abstention argument. The U.S. Court of Appeals for the Sixth Circuit reversed and held that allowing the Commission jurisdiction over Dayton would violate the First Amendment.

Question

Should the district court have abstained from adjudicating the case?

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