Chloe DeOnna v. Centre Hills Country Club

Centre Hills Country Club (CHCC) (defendant), a Pennsylvania golf club, was exempt from taxation under 26 U.S.C. § 501(c) and was managed by a nine-person board of directors. Usage of CHCC’s facilities was generally limited to CHCC members and their escorted guests. Membership required an application, sponsorship by a current member, a background check, and a board vote approving admission. Admission, which required payment of initiation fees and annual dues, automatically included the new member’s spouse, although the spouse was not included in the 400-person membership quota. Former CHCC employee Chloe DeOnna (plaintiff) sued CHCC for sex discrimination violating Title VII of the Civil Rights Act of 1964 (Title VII) and the Pennsylvania Human Rights Act. CHCC argued that it was not subject to Title VII because it fell under an exception for bona fide membership clubs exempt from taxation under § 501(c). DeOnna argued that CHCC did not qualify as a bona fide membership club because it was not private. In support, DeOnna showed that nonmembers occasionally had access to CHCC facilities during third-party events or golf tournaments and that CHCC had a public website, which DeOnna argued constituted advertising. The district court considered the parties’ arguments when ruling on CHCC’s motion for summary judgment.