John Doe v. Catholic Relief Services

John Doe filed suit against his employer CRS after the organization revoked health insurance coverage for his spouse solely because his spouse is a man. The District Court found that CRS violated the Equal Pay Act and Title VII by engaging in sex-based discrimination. CRS appealed the decision, asserting, among other issues, that the church autonomy doctrine and the Religious Freedom Restoration Act (RFRA) shield it from liability.

Our amicus brief argues that the church autonomy doctrine is limited in scope and applies only to internal disputes over religious doctrine and ministerial employment. The church autonomy doctrine does not allow religious employers to sidestep neutral, generally applicable civil rights laws. Such an interpretation would effectively grant religious employers blanket immunity from anti-discrimination laws, a contention that has been explicitly rejected by the U.S. Supreme Court.

The brief also argue that RFRA only restricts the government, not private citizens, and thus cannot be used as a defense in a private-party lawsuits. Because this case involves a private party seeking to enforce federal employment protections, RFRA offers no legal shield for CRS’s conduct.