Petitioner was employed at a non-profit organization affiliated with the Church of Jesus Christ of Latter-Day Saints. The organization was open to the public, but he got fired because he was not a member of the Church. He claimed that he was religiously discriminated against. The Church argued that its religious affiliation exempted it from being subject to religious discrimination charges. This exemption was instituted in the Civil Rights Act of 1964 (702).
In a unanimous decision, the Court found that the exemption in the Civil Rights Act of 1964 was constitutional because it was related to a legitimate interest.
|Majority Opinion: (Justice White)|
The Court used the Lemon test to check the constitutionality of the exemption of religous organizations from religious discrimination laws. "Under the Lemon analysis, it is a permissible legislative purpose to alleviate significant governmental interference with the ability of religious organizations to define and carry out their religious missions." The state's interest in guarding against interference in religion allows it to not require religous organizations to strictly follow laws that apply to others. The exemption is rationally related to this end that it seeks to further.
This decision uses neutrality as an important criteria in ruling on Establishment Clause cases. The exemption to the Civil Rights Act of 1964 does not endorse any particular religion and is limited to enhancing a legitimate end.
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