Dias v. Archdiocese of Cincinnati

Christa Dias (plaintiff) worked as a computer-technology coordinator at two schools run by the Archdiocese of Cincinnati (defendant). Dias’s employment contract included a morals clause, which stated that all employees must comply with the Roman Catholic Church’s philosophy and teachings. Dias was in a same-sex relationship but did not inform anyone at the school because she was aware that the relationship violated the morals clause. Dias then became pregnant through artificial insemination, and informed Principal Jennifer O’Brien of the pregnancy. O’Brien told Dias that she would be terminated because she was pregnant and unmarried. Dias told O’Brien that she had become pregnant through artificial insemination rather than by premarital sex. O’Brien told Dias that she would still be terminated because pregnancy through artificial insemination violated the morals clause. Dias filed suit, alleging that the termination amounted to pregnancy discrimination and breach of the employment contract. The archdiocese filed a motion to dismiss on the ground that the ministerial exception to Title VII was applicable and that because Dias breached the morals clause, she could not sue to enforce the employment contract. The court denied the motion to dismiss. During discovery, the archdiocese found additional facts relating to the applicability of the ministerial exception, that Dias had violated the morals clause of the employment contract, and that the archdiocese was not a proper defendant. Accordingly, the archdiocese moved for summary judgment again. In response, Dias also moved for summary judgment, arguing that the ministerial exception to Title VII was not applicable, that she should prevail on the pregnancy discrimination, and that under the integrated employer doctrine, the archdiocese was a proper defendant.