Equal Employment Opportunity Commission v. Preferred Management Corp.

Sondra Sievers, a Catholic, was a branch manager for Preferred Management Corporation’s (Preferred) (defendant’s) home-healthcare agency. Jackie Steuerwald, Preferred’s co-owner and chief executive officer, was a born-again Christian who believed that Preferred was God’s home-healthcare agency. Steuerwald infused her religious beliefs in Preferred’s regular operations. For example, Preferred’s primary mission was “to be a Christian dedicated provider of quality health care,” Preferred’s evangelism-and-discipleship subcommittee prayed for Preferred employees’ salvation, Steuerwald blessed Preferred’s office buildings, and Preferred’s organizational chart depicted a wheel with Jesus at the center and Preferred’s departments at the spokes. Sievers claimed that Steuerwald demoted and ultimately discharged Sievers because Sievers refused to subscribe to Preferred’s Evangelical practices and beliefs. Steuerwald contested that the demotion was based on Sievers’s poor performance, as indicated by an employee survey. Of the 59 surveys distributed at Sievers’s branch, 34 employees responded, and three employees’ responses had negative comments about Sievers. Sievers’s supervisor believed that Preferred designed the survey to obtain negative results about Sievers. Before the survey, Sievers’s performance evaluations were at least satisfactory. Based on the survey, Steuerwald required Sievers to participate in Nellie Foster’s Leader in the Making program. The program’s documents had religious connotations. Foster repeatedly asked Sievers about Sievers’s recent sins. Sievers ultimately began crying and responded, “I am a Catholic, and I discuss my sins with my priest.” Foster concluded that Sievers was not a candidate for leadership training. Steuerwald refused to return Sievers to her management position and replaced her with Sue Klein, who had no management experience but had religious views that aligned with Steuerwald’s. Steuerwald fired Sievers three months later. Preferred also claimed that Sievers learned of alleged employment misconduct and did not intervene, lost some of Preferred’s business, and approved hiring an employee who did not meet minimum-experience requirements, but evidence contradicted these claims. The Equal Employment Opportunity Commission (EEOC) (plaintiff) sued Preferred on Sievers’s behalf, alleging religious harassment and disparate treatment in violation of Title VII of the Civil Rights Act of 1964. Preferred moved for summary judgment.