At the intersection of employment, civil rights, and religious freedom comes Hamilton v. Southland Christian School, Inc. from the 11th Circuit. In that case, a small Christian school had fired a teacher after she had sought maternity leave, purportedly because she had conceived the child before her recent marriage. On appeal, the 11th Circuit reversed the District Court’s grant of summary judgment in favor of the school on Hamilton’s Title VII pregnancy discrimination claim, finding that Hamilton had presented sufficient evidence that the decision to fire her was more about her pregnancy and request for maternity leave, instead of her admission concerning premarital sex. As such, the Court ruled that resolving this genuine issue of material fact should be reserved for the jury.
The 7th Circuit issued an opinion on broken compensation agreements for 40,000 state employees in Illinois. In Council 31 of the Am. Fed. of St., Cty., and Mun. Employees v. Quinn, the state froze the pay of unionized employees, repudiating agreements with the union. The 7th Circuit found that the union’s claim of violations of the Contracts Clause and Equal Protection clause was barred by the Eleventh Amendment. The court noted that the state’s actions did not bar a breach of contract suit. There was a rational relationship between those actions and a legitimate governmental purpose, precluding an equal protection claim.