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Ohio CIV. Rgts. Comm’n v. Dayton Chr. Pub. Schs., 477 U.S. 619 (1986)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Ohio CIV. Rgts. Comm’n v. Dayton Chr. Pub. Schs., 477 U.S. 619 (1986)
Ohio Civil Rights Commission v. Dayton Christian Public Schools, Inc. No. 85-488 Argued March 26, 1986 Decided June 27, 1986 477 U.S. 619
APPEAL FROM THE UNITED STATES COURT OF APPEALS FOR
THE SIXTH CIRCUIT
Syllabus
Appellee Dayton Christian Schools, Inc. (Dayton), a private nonprofit corporation that provides elementary and secondary education, requires that its teachers subscribe to a particular set of religious beliefs, including belief in the internal resolution of disputes through the "Biblical chain of command." As a contractual condition of employment, teachers must agree to present any grievance to their immediate supervisor, and to acquiesce in the final authority of Dayton’s board of directors, rather than to pursue a remedy in civil court. After a pregnant teacher was told that her employment contract would not be renewed because of Dayton’s religious doctrine that mothers should stay home with their preschool age children, she contacted an attorney, who threatened Dayton with litigation under state and federal sex discrimination laws if it did not agree to rehire the teacher for the coming school year. Dayton then rescinded its nonrenewal decision, but terminated the teacher because of her violation of the internal dispute resolution doctrine. The teacher then filed a charge with appellant Ohio Civil Rights Commission, alleging that under Ohio statutes Dayton’s original nonrenewal decision constituted unlawful sex discrimination and its termination decision unlawfully penalized her for asserting her rights. Ultimately, the Commission initiated administrative proceedings against Dayton, which answered the complaint by asserting that the First Amendment prevented the Commission from exercising jurisdiction over it, since its actions had been taken pursuant to sincerely held religious beliefs. While the administrative proceedings were pending, Dayton and others (also appellees here) filed this action in Federal District Court, seeking an injunction against the state administrative proceedings on the ground that any investigation of Dayton’s hiring process or any imposition of sanctions for its nonrenewal or termination decisions would violate the Religion Clauses of the First Amendment. Without addressing the Commission’s argument that the court should abstain from exercising its jurisdiction, the District Court refused to issue an injunction, holding, inter alia, that the Commission’s proposed action would not violate the First and Fourteenth Amendments. The Court of Appeals reversed, holding that the Commission’s exercise of jurisdiction would violate both the Free Exercise Clause and the Establishment Clause of the First Amendment.
Held:
1. This Court has appellate jurisdiction over this case under 28 U.S.C. § 1264(2), which authorizes review of a court of appeals’ decision holding a state statute unconstitutional as applied to the facts of the case. Here, the Court of Appeals expressly held that the Ohio statutory provisions relied on by the teacher, as applied to authorize the administrative proceedings, were repugnant to the Religion Clauses. P. 626.
2. The District Court should have abstained from adjudicating this case under Younger v. Harris, 401 U.S. 37, and its progeny. Younger, which held that a federal court should not enjoin a pending state criminal proceeding except when necessary to prevent great and immediate irreparable injury, was based on concerns for comity and federalism. Such concerns are equally applicable to other types of state proceedings, including state administrative proceedings, judicial in nature, in which important state interests are vindicated, so long as, in the course of those proceedings, the federal plaintiff will have a full and fair opportunity to litigate his constitutional claim. The elimination of prohibited sex discrimination is a sufficiently important state interest to bring the present case within the ambit of the Younger doctrine, and there is no reason to doubt that Dayton will receive an adequate opportunity to raise its constitutional claims. Even assuming that Ohio law is such that the Commission may not consider the constitutionality of the statute under which it operates, it is sufficient that, under Ohio law, constitutional claims may be raised in state court judicial review of the administrative proceedings. Pp. 626-629.
766 F.2d 932, reversed and remanded.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, POWELL, and O’CONNOR, JJ., joined. STEVENS, J., filed an opinion concurring in the judgment, in which BRENNAN, MARSHALL, and BLACKMUN, JJ., joined, post, p. 629.
Contents:
Chicago: U.S. Supreme Court, "Syllabus," Ohio CIV. Rgts. Comm’n v. Dayton Chr. Pub. Schs., 477 U.S. 619 (1986) in 477 U.S. 619 477 U.S. 620–477 U.S. 621. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=HPV3U49Y2TTUPAT.
MLA: U.S. Supreme Court. "Syllabus." Ohio CIV. Rgts. Comm’n v. Dayton Chr. Pub. Schs., 477 U.S. 619 (1986), in 477 U.S. 619, pp. 477 U.S. 620–477 U.S. 621. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=HPV3U49Y2TTUPAT.
Harvard: U.S. Supreme Court, 'Syllabus' in Ohio CIV. Rgts. Comm’n v. Dayton Chr. Pub. Schs., 477 U.S. 619 (1986). cited in 1986, 477 U.S. 619, pp.477 U.S. 620–477 U.S. 621. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=HPV3U49Y2TTUPAT.
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