Eva Palmer v. Liberty University, Incorporated, No. 21-2390 (4th Cir. 2023)
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In consolidated appeals, Plaintiff challenged the district court’s award of summary judgment to defendant Liberty University, Inc. (“Liberty”) on Palmer’s claim of age discrimination, pursued under provisions of the Age Discrimination in Employment Act (the “ADEA”) (the “Statutory Ruling”). On the other hand, Liberty, by cross-appeal, challenged an earlier award of summary judgment that was made to Plaintiff, in which the court ruled that Plaintiff was not a “minister” for purposes of the First Amendment’s so-called “ministerial exception” (the “Constitutional Ruling”).
The Fourth Circuit affirmed the Statutory Ruling, dismissed Liberty’s cross-appeal, and vacated the Constitutional Ruling. The court explained that it agreed with the district court that Plaintiff failed to produce sufficient evidence of age-based discrimination to overcome Liberty’s summary judgment motion on that issue. Accordingly, the court was satisfied to affirm the Statutory Ruling in favor of Liberty. Moreover, in light of that disposition — and pursuant to the constitutional avoidance doctrine — the court refrained from resolving whether Plaintiff was a minister for purposes of the First Amendment’s ministerial exception. As a result, the court wrote it was obliged to dismiss Liberty’s cross-appeal and vacate the Constitutional Ruling.
The court issued a subsequent related opinion or order on July 5, 2023.
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