10-29-2026
Catholic Relief Services (CRS), which is affiliated with the Catholic Church, provides assistance to the poor and vulnerable overseas. The non-profit employs over 8,000 people, and only those employees who hold “representational” positions are required to adhere to the tenets of the Catholic faith.
John Doe encountered a CRS recruiter at a job fair. He fit their job description for a data analyst, managing data and databases to facilitate decision-making. Doe shared that he was a gay, married man. He asked the recruiter whether CRS would cover his husband as a dependent on the employee health benefit plan. The job fair recruiter assured Doe that his husband would be covered. Doe took the job and enrolled his husband. Five months later, CRS notified Doe that his husband’s enrollment was a mistake and that providing dependent benefits to his husband was contrary to its religious values and terminated his husband’s benefits.
The district court granted Doe’s summary judgment motion as to his discrimination claims under Title VII and Maryland’s anti-discrimination statute. CRS appealed to the Fourth Circuit Court of Appeals, arguing that it was exempt as a religious employer under both Title VII and the state anti-discrimination statute.
The Court rejected CRS’s arguments, determining that the organization’s request for immunity was “extremely broad and nearly unbounded,” and beyond the requirements of any statute or constitutional provision. The Court concluded Title VII’s prohibition of employment decisions based on race, sex, or national origin applied to religious organizations, even when their decision was motivated by religion. Religious employers may give preference to individuals who share their faith and may take employment action when an employee's conduct or beliefs conflict with the organization's religious standards. However, employment decisions cannot be based on protected characteristics such as race, sex, or national origin. The ministerial exception did not apply in this case because Doe’s duties were “indistinguishable” from those duties performed at secular organizations.
CRS also argued that the Religious Freedom Restoration Act barred enforcement of those statutes against it, and that the U.S. Constitution’s Free Exercise Clause made the employment statutes unconstitutional as applied in the case. The Fourth Circuit rejected these arguments as well in the 173-page opinion. The appellate court held that the RFRA did not apply to suits between private parties, consistent with the holdings from many other circuit courts.