Conlon v. InterVarsity Christian Fellowship/USA, No. 14-1549 (6th Cir. 2015)Annotate this Case
The website for InterVarsity Christian Fellowship/USA states that all employees must annually reaffirm their agreement with IVCF’s Purpose Statement and Doctrinal Basis. The website includes statements that: Pursuant to the Civil Rights Act of 1964 (42 U.S.C. 2000e-1(a)) (Title VII), IVCF has the right to, and does, hire only candidates who agree with IVCF’s Purpose and Doctrinal Basis and that the status of [IVCF] as an Equal Opportunity Employer does not prevent the organization from hiring staff based on their religious beliefs so that all staff share the same religious commitment. Conlon began working at IVCF in Michigan in 1986 as a spiritual director, involved in providing religious counsel and prayer. In 2011, she informed IVCF that she was contemplating divorce. IVCF put her on paid (later unpaid) leave. When her marital situation continued to worsen despite counseling efforts, IVCF terminated her employment. After exhausting administrative remedies, Conlon sued IVCF and her supervisors under Title VII and Michigan law, alleging that male employees were treated differently. IVCF claimed ministerial exception to employment laws. The district court dismissed, holding that the First Amendment’s ministerial exception barred all of Conlon’s claims. The Sixth Circuit affirmed.