Cases & Developments

Opinion affirming summary judgment in favor of the defendant.  Plaintiff, a former high school music teacher with the Brownsburg Community School Corporation who asserted that his sincerely held religious beliefs prevented him from engaging in any action to “promote gender dysphoria,” brought discrimination and retaliation claims against Brownsburg after he was forced to resign rather than comply with the school’s Name Policy requiring teachers to call students by their first names as listed in the school’s database.  The school initially permitted him to refer to all students by their last names only, but it withdrew the accommodation because it was harming students and disrupting the learning environment.  In affirming summary judgment in favor of Brownsburg on his failure to accommodate claim, the Seventh Circuit held that while plaintiff had met his prima facie burden, the school had sufficiently demonstrated that continuing the accommodation posed an undue burden on its mission of educating students according to its established theory and practice.  The court similarly held that plaintiff’s retaliation claim failed because (1) the school worked with him for a full school year to find a workable adjustment and (2) he presented no evidence of pretext regarding the school’s determination that the accommodation had harmed students.