Teton Therapy v. Rohrbacher

 Julie A. Rohrbacher filed a lawsuit in 2018 against the Teton Therapy company, a physical and occupational therapy company based in Wyoming. Rohrbacher filed a suit against the company on the grounds of religious discrimination. The Wyoming firm made company workers enroll in and attend Church of Scientology courses in order to complete training for the company. Rohrbacher claimed that the owner of the company, Jeff McMenamy, refused to promote her for a management position in 2013, unless she completed a training course in Clearwater, Florida, where the headquarters of the Church of Scientology are located. After declining to attend the Church of Scientology training courses in Florida, Rohrbacher was denied a promotion then fired from the company. Owner, Jeff McMenamy, claims he does not practice Scientology, but believes that the training drawn from the Church was, “effective for business purposes.” Rohrbacher expressed her discomfort with attending a training course associated with the Church of Scientology because it not only forced a certain religion on her, but did not align with her own religious beliefs. Rohrbacher sued the company under Title VII of the Civil Rights act of 1964 for both religious harassment and religious discrimination. The suit was recently settled in January of 2020. 

This case not only exhibits the issue of religious harassment and discrimination, but also demonstrates the issue of free exercise of religion. Under Title VII of the Civil Rights Act, employees are protected, “from employment discrimination based on race, color, religion, sex and national origin.” The salient question of this case is whether it was constitutional for the Teton Therapy company to fire Rohrbacher because she would not take the company mandated courses due to religious objections to the Church of Scientology. Although the lawsuit itself did not include the free exercise clause in the argument, Rohrbacher’s own religious beliefs were suppressed when she expressed her disagreement with the teachings of the Church of Scientology because of the way they did not align with her own, and she was dismissed from her job. This case not only deals with the rights of Julie Rohrbacher, but it is important to consider the rights of the Teton Therapy Company as well, and whether or not they can institute religious practices as a part of their business and employee training. 

Had this case not been settled by the Teton Therapy company, I believe, and would agree,  the court would have ruled in favor of Rohrbacher on the grounds of Title VII that prohibits employers from discriminating against their employees on the basis of religion. In this case, the rights of Rohrbacher were clearly infringed upon since the only way she was eligible for a promotion was if she forfeited her own beliefs and participated in Church of Scientology courses mandated by the company. In the 2015 case of Equal Employment Opportunity Commission v Abercrombie & Fitch Stores Inc, the court ruled that employers should be liable under Title VII of the Civil Rights Act “for refusing to hire an applicant based on a religious observance or practice” even if the employer did not have direct knowledge that a religious accommodation was required. In this case, although Rohrbacher was already an employee, the opportunity to be hired into a higher level position within the company was unattainable unless she took the company mandated Scientology courses. Though the case of Rohrbacher did not present religious accommodations, this case still upholds Title VII and reaffirms that a company cannot discriminate against an employee who does not agree with a company policy due to religious reasons. This case was also extremely important for future issues of protecting employees from religious discrimination or harassment from employers, whether it involved an accomodation or not. 

I think this case would be very different if the Teton Therapy Company fired Rohrbacher and objected to her lack of compliance because of their own sincere religious beliefs. For example, in the 2014 case of Burwell v Hobby Lobby Stores, the court ruled in a 5-4 decision that it was constitutional for a for-profit corporation to deny its employees health coverage of contraception “to which the employees would otherwise be entitled based on the religious objections of the company's owners.” This landmark decision is beneficial for companies by the way it gives them the right to use their religion as a reason to object to or deny their employees certain benefits. This case establishes and ensures that companies’ religious rights are protected and not burdened significantly. However, in the case of Teton Therapy, the company and the owner Jeff McMenamy did not demonstrate any sincere beliefs or even affiliation with the Church of Scientology, like the Green family did with principles of the Christian faith in the Hobby Lobby case. It is important to recognize that there are competing interests between the internal affairs of religious groups or companies, and protecting the groups’ employees from discrimination. These interests can easily conflict and become a problem, but that does not appear to be the case in regard to Teton Therapy and Rhorbacher. McMenamy outwardly stated that he did not practice the religion himself, and therefore has no valid reason to force his employees, like Rohrbacher, to participate in Church of Scientology courses, and punish them if they do not comply due to religious reasons or disagreement. The Teton Therapy company mandated Church of Scientology training courses are unconstitutional because they violate Title VII of the Civil Rights Act by religious discrimination, and infringe upon Julie Rohrbacher’s guaranteed First Amendment right to free exercise of religion.