Crystal Chambers v. Omaha Girls Club, Inc.

Crystal Chambers (plaintiff) worked as an arts and crafts instructor at the Omaha Girls Club (the club) (defendant). Chambers was unmarried and became pregnant. The club terminated Chambers for violating the role-model rule, which forbade single-parent pregnancies among staff. Chambers filed a Title VII action in federal district court against the club. Chambers claimed that the club’s role-model rule had a disparate impact on race and, by adopting the rule, the club had engaged in disparate treatment that violated the Pregnancy Discrimination Act. The club asserted a business-necessity defense to Chambers’ disparate-impact claim. The club argued that the rule was related to the club’s purpose of providing girls with opportunities because allowing single-parent pregnant woman to work with girls would convey the message that the club condoned teenage pregnancies. At trial, the club presented expert testimony on the positive effect that the role-model rule could have on reducing teenage pregnancies. However, the club did not produce any validated studies. The district court found that Chambers had established that the role-model rule had a disparate impact on race, but that the club had established a business-necessity defense because there was a manifest relationship between the rule and the club’s fundamental purpose. The district court dismissed the disparate-impact claim. The district court also dismissed the disparate-treatment claim. The district court explained, without further analysis, that the role-model rule constituted a bona fide occupational-qualification exception, which relieved the club from liability on the disparate-treatment claim. Chambers appealed.