A Federal Court has found in favor of a teacher who brought a discrimination claim against the Roman Catholic Archdiocese of Cincinnati in respect of her dismissal after becoming pregnant by artificial insemination.
Christa Dias, an Ohio computer teacher in two diocesan schools, was dismissed from her job in October, 2010 after becoming pregnant by way of artificial insemination. Her dismissal was on the grounds that Dias had violated her contract, which required her to comply with the teachings and philosophies of the Catholic Church. The Catholic Church regards artificial insemination as immoral, and a violation of Church doctrine.
Dias claimed that her dismissal was unlawful because it violated Federal and State anti-discrimination laws, which outlaw discrimination on the grounds of pregnancy or marital status.
The case required the Court to decide whether anti-discrimination legislation took precedence over a contractual right to dismiss an employee. Whilst the Archdiocese argued that the case involved a clear breach of contract by Dias, which entitled the Archdiocese to dismiss her, Dias argued that the dismissal was solely because she was pregnant and unmarried, amounting to discrimination. Ultimately, the jury agreed with Dias. The jury awarded Dias $51,000 in back pay, $20,000 in compensatory damages and $100,000 in punitive damages, a total of $171,000.
Dias had sued the Archdiocese and two diocesan schools. Her attorney, Robert Klingler, suggested to the Court that a figure as high as $637,000 was appropriate for damages. The Court found the Archdiocese liable for the $171,000 award, but did not make any order against the schools. Dias later commented that she was satisfied with the award.
A spokesman for the Archdiocese, Dan Andriacco, said that the Archdiocese had always viewed the case as being about the Archdiocese's right to enforce a contract against an employee who had broken that contract. The attorney for the Archdiocese and the schools, Steve Goodin, said he was disappointed in the verdict, but relieved that the schools were spared the financial hardship of having to pay damages. Goodin argued in Court that Dias had intended to breach her contract from its beginning. To illustrate this argument, he told the Court that Dias was gay, but had kept this fact secret, knowing that homosexual acts would also violate Church teachings and be in breach of her contract. Neither party claimed that the dismissal was because of Dias' homosexuality. The jurors were instructed that sexual orientation was not a factor that could be considered in their deliberations as to the reason for dismissal.
The Ohio decision has called into question the general rights of religious organizations to dismiss employees for breach of contract on the grounds of immorality or acting contrary to Church teachings when the circumstances may also be seen as discrimination. One such case concerns the dismissal of Carla Hale, a gay woman fired from her job as physical education teacher by the Diocese of Columbus for breaching a morality clause in her contract by publishing the name of her gay partner in a newspaper obituary. Hale has filed a complaint of discrimination and is considering a civil law suit.
