In a recent development, the United States District Court for the Western District of Washington at Seattle has granted a motion for reconsideration in the case of Aubry McMahon against World Vision, Inc. The court had previously granted World Vision’s motion for summary judgment and denied McMahon’s motion for partial summary judgment. The court’s decision was based on the Church Autonomy Doctrine, which it had concluded barred McMahon’s claims for sex, sexual orientation, and marital status discrimination.
McMahon had been offered a job by World Vision, but the offer was rescinded because her same-sex marriage was seen as a violation of World Vision’s Standards of Conduct (SOC), which prohibit sexual conduct outside of a Biblical marriage between a man and a woman. McMahon moved for reconsideration of the court’s decision, arguing that her claims could be resolved using “neutral principles of law” and did not require questioning the reasonableness, validity, or truth of a religious doctrine or practice.
The court agreed with McMahon’s assertion that World Vision’s Biblical marriage SOC is facially discriminatory under controlling precedent. It noted that if McMahon were a man married to a woman, she would not have violated World Vision’s Biblical marriage policy and her job offer would not have been rescinded. The court concluded that McMahon was treated differently because of her sex, sexual orientation, and marital status.
The court also agreed with McMahon that it should not have analyzed her claims under the burden-shifting framework set forth in Opara v. Yellen, as her claims of discriminatory treatment were based on World Vision’s facially discriminatory Biblical marriage SOC. The court concluded that the Church Autonomy Doctrine does not bar McMahon’s claims, as they can be established using neutral principles of law.
The court’s decision to grant McMahon’s motion for reconsideration and vacate the final judgment in favor of World Vision represents a significant development in this case. The case will now proceed further in light of the court’s new findings. (Source: United States District Court for the Western District of Washington at Seattle, Case No. C21-0920JLR, Document 44, Filed 07/24/23)