Dayton Christian Schools required its teachers to subscribe to certain religious beliefs. Teachers were required to submit any grievances to their supervisor and respect whichever resolution he offered rather than resort to civil court proceedings (this process was termed the "Biblical chain of command"). When a teacher became pregnant, the school board refused to offer her a contract renewal because it believed that mothers should remain at home with their preschool children. When the woman sought legal counsel and threatened a lawsuit, the school terminated her for violating the internal resolution requirement. The woman filed a grievance with the Ohio Civil Rights Commission claiming sex discrimination, and the school sought an injunction against its investigation because the schools' hiring practices were based on their sincere religious beliefs.
In a unanimous decision, the Court allowed the Ohio Civil Rights Commission to continue its investigation.
| Majority Opinion: (Justice Rehnquist) |
In an earlier decision (Younger v. Harris), the Court ruled that an injunction against a state criminal proceeding should only be offered if there is a danger of severe and immediate irreparable harm. The school district will have an appropriate chance to make its constitutional claims at the conclusion of the investigation. The elimination of sexual discrimination is a sufficient state interest to allow the investigation to continue. "We therefore think that however Dayton's constitutional claim should be decided on the merits, the Commission violates no constitutional rights by merely investigating the circumstances of Hoskinson's discharge in this case, if only to ascertain whether the ascribed religious-based reason was in fact the reason for the discharge."
Religious organizations cannot use their religious freedom to prevent an initial investigation. The proper time for them to assert their claims is after the conclusion of the investigation.
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