Redhead v. Conference of Seventh-Day Adventists
Plaintiff Jewel Redhead sued defendant Conference of Seventh-day Adventists for unlawful discrimination under Title VII and the New York State Human Rights Law, alleging termination from her teaching position due to being pregnant and unmarried. The defendant moved for summary judgment, arguing a lack of jurisdiction due to the 'ministerial exception' and that the termination was for violating church doctrine. The court initially denied summary judgment in 2006. Following a Second Circuit decision in Rweyemamu v. Cote, defendant renewed its summary judgment application. The court denied the renewed application, holding that while the ministerial exception prevents challenging the validity of the religious code, it does not prevent a secular employee like Redhead from proving the code was applied in a discriminatory manner based on sex and pregnancy. The court also denied the defendant's request for a certificate of appealability.