Doe v. Salvation Army in the U.S., No. 11-3019 (6th Cir. 2012)
Annotate this CaseDoe sued the Salvation Army and its warehouse supervisor, claiming employment discrimination under the Rehabilitation Act, 29 U.S.C. 794(a). The supervisor allegedly inappropriately asked him in an interview what kind of medications Doe was taking and refused to hire Doe as a truck driver when Doe responded that he was taking “psychotropic” medications. The Sixth Circuit reversed dismissal, holding that material issues of fact existed as to Doe’s disability and the legitimacy of the warehouse’s safety concerns. On remand, the court granted the Salvation Army summary judgment on the basis that it was a religious organization and not principally engaged in social services. The Sixth Circuit reversed. The statutory definition of “program or activity” permits consideration of the whole organization if the organization is principally engaged in the business of providing social services. That the Salvation Army views its social service as a way of spreading its spiritual teachings is not dispositive; an activity can be both.
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