John Doe v. Catholic Relief Services

Circuit 4Oct 16, 2026

Split Score

SplitScore: 71/100

Case Summary

Disposition

Affirmed in Part

The Fourth Circuit held that Catholic Relief Services violated Title VII, the Equal Pay Act and Maryland’s Fair Employment Practices Act by denying spousal health-insurance benefits to a gay employee, rejecting CRS’s defences rooted in statutory religious exemptions, RFRA and the First Amendment. The court ruled that neither Title VII’s §702 exemption nor the church-autonomy doctrine shields a religious employer from liability when the challenged action is also based on sex-related grounds, and it affirmed the district court’s judgment for the employee (while dismissing the EPA appeal as moot).

View Full Opinion Document (PDF)

Circuit Split Identified

Legal Issue

Scope of Title VII’s §702 religious-employer exemption—does it bar all Title VII liability whenever a challenged employment action is motivated by religious belief, even if the action also discriminates on another protected basis such as sex/sexual-orientation?

Circuit Positions

Circuit 3Circuit 7Circuit 9Circuit 10

Broad reading – §702 shields religious employers from any Title VII claim so long as the employment action is motivated by sincerely held religious belief, even if the action also discriminates on sex, race, or national origin.

Circuit 4(this circuit)

Narrow reading – §702 removes only claims of religious discrimination; it affords no defense when the employment action also discriminates on another protected ground (e.g., sex).

Conflict Summary

Some circuits construe §702 broadly, holding that a religious organization is completely exempt from Title VII whenever it acts on a sincerely-held religious belief, even if the decision also discriminates on sex, race, or other protected characteristics. Other circuits, including the Fourth in this case, read §702 narrowly, limiting the exemption to decisions that discriminate only on religious grounds; if the same decision also discriminates on sex, race or national origin the exemption does not apply and Title VII liability may attach.

Parties & Counsel

Parties

Appellant:Catholic Relief Services
Appellee:John Doe

Legal Counsel

Appellant:Gallagher Evelius & Jones LLP (Joseph C. Dugan, Brandon K. Wharton)
Appellee:Nusinov Smith LLP (Anthony J. May); Brown, Goldstein & Levy; Gilbert Employment Law P.C.