Billard v. Charlotte Catholic High School, No. 22-1440 (4th Cir. 2024)
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Lonnie Billard, a former teacher at Charlotte Catholic High School (CCHS), sued the school for sex discrimination under Title VII after he was fired for his plans to marry his same-sex partner. The district court granted Billard's motion for summary judgment and denied CCHS's motion, which raised several affirmative defenses, both statutory and constitutional.
The district court found that CCHS had indeed fired Billard because of his plans to marry his same-sex partner, which amounted to sex discrimination as defined by Title VII. The court rejected CCHS's affirmative defenses, including its interpretation of Title VII's religious exemption, its defense under the Religious Freedom Restoration Act, and its First Amendment defenses. The court also ruled on the ministerial exception, despite CCHS's waiver of that defense, and found that Billard did not satisfy the criteria for the ministerial exception.
On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court's decision. The appellate court concluded that because Billard played a vital role as a messenger of CCHS's faith, he falls under the ministerial exception to Title VII. Therefore, the court instructed the district court to enter judgment for CCHS.
The court issued a subsequent related opinion or order on May 9, 2024.
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