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15-Employee Requirement for Churches

Church affiliates do not have to combine overall number of employees to meet Title VII rule.

A federal appeals court ruled that the 15-employee requirement under Title VII of the Civil Rights Act of 1964 could not be met by combining the employees of a church and affiliated entity, since they were not sufficiently related organizationally. A maintenance worker (the "plaintiff") at a church-affiliated apartment building (the "Manor") sued the Manor as a result of his supervisor's acts of sexual harassment in violation of Title VII of the Civil Rights Act of 1964. Title VII prohibits any employer, including a church, that is engaged in commerce and that has 15 or more employees from discriminating in any employment decision as a result of a person's race, color, national origin, sex (including sexual harassment), or religion.

The Manor is a not-for-profit corporation formally governed by its members, all of whom are also members of the church. The members select an 11-member board ...

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Posted:
  • November 1, 2012

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