Garrick v. Moody Bible Institute

Last modified 2023.12.05


  • Status Ongoing
  • Type Counsel
  • Court U.S. Court of Appeals
  • Issues Discrimination by Employers, Fighting Discrimination, Religious Discrimination in Schools

Case Documents

Janay Garrick was a teacher in the communications department at Moody Bible Institute, where she designed and taught secular courses on topics such as the role of words as core communicative tools and grant-writing for NGOs. Soon after being hired, Janay began experiencing and witnessing rampant sex discrimination. She was denied benefits offered to her male counterparts and directed to teach a heavier course load than similarly situated male colleagues. She was also the subject of demeaning and hostile behavior: male colleagues critiqued her clothing; openly ridiculed her; and questioned whether women could even complete basic onboarding documents. Janay additionally saw the way that female students suffered on campus. They were denied entry into certain academic programs because of their sex, ostracized because of their sexuality, and publicly humiliated. 

But when Janay tried to do something to protect herself and her students, Moody made it worse. She was denied a promotion for which she was qualified. Her supervisors began fictionalizing poor performance reviews in an effort to push her out. And when that failed, Moody argued–for the first time–that Janay’s views on gender equity made her incompatible with the school, which has religious views that call for the subordination of women in certain respects. But Moody knew about Janay’s views on gender equity from the beginning–she was vocal about them during her hiring process. Meanwhile, several male employees shared her egalitarian views and several joined her in speaking up about sexism on Moody’s campus. Janay’s male colleagues suffered none of the harassment or retaliation directed at Janay.

Eventually, Moody succeeded in firing Janay, and Janay brought a Title VII lawsuit. Representing herself in the trial court, Janay alleged gender discrimination and explained that Moody used religious differences as a pretext for firing her. Moody moved to dismiss Janay’s complaint, arguing in part that the church-autonomy doctrine barred her claims.

The district court denied the motion and Moody immediately appealed to the U.S. Court of Appeals for the Seventh Circuit. Americans United then began representing Janay. We filed a brief on Janay’s behalf in September 2023, explaining that it would be procedurally improper to consider the school’s appeal and that, even if the Seventh Circuit could somehow consider the appeal, it should affirm the trial court’s decision. Americans United Litigation Counsel Bradley Girard presented oral argument to the Seventh Circuit on December 5, 2023.

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