## Facts

- Leigh Cline worked at a Catholic parish school in the Diocese of Toledo, initially as a substitute and then under annual one-year “Teacher-Minister” contracts.
- In the 1995–1996 school year, she taught second grade and had religious duties, including daily religious instruction, accompanying students to Mass, and preparing students for sacraments.
- Cline signed yearly documents characterizing her as a “teacher/minister” expected to reflect Catholic values “by word and example.”
- After marrying in early 1996, Cline became visibly pregnant; school officials inferred from the pregnancy’s timing that she had engaged in premarital sex contrary to Church teaching.
- The school, through Father Herbert J. Willman, declined to renew her contract for the next school year and stated the reason was violation of Church teaching on premarital sex.
- Cline received favorable evaluations and presented evidence her teaching was praised shortly before nonrenewal.
- Cline alleged the morality policy was not enforced in a gender-neutral manner because men were not similarly investigated or disciplined; defendants conceded the conclusion of premarital sex was drawn solely from her pregnancy.
- Cline filed Title VII and Ohio civil-rights claims, plus Ohio-law claims for breach of contract and promissory estoppel; the district court granted summary judgment to defendants on all claims.

## Issues

1. Whether Cline produced sufficient evidence to establish a prima facie case of pregnancy discrimination under Title VII and Ohio Rev. Code § 4112 when her one-year contract was not renewed after she became visibly pregnant.
2. Whether the district court improperly evaluated the employer’s stated nondiscriminatory reason at the prima facie stage under the *McDonnell Douglas* framework.
3. Whether the record permitted a reasonable jury to find the stated “premarital sex” rationale was a pretext for pregnancy/sex discrimination, including based on unequal enforcement against women.
4. Whether nonrenewal of a fully performed one-year contract, with no renewal right, supports breach of contract or promissory estoppel under Ohio law.

## Decision

- The Sixth Circuit affirmed in part and reversed in part.
- It reversed summary judgment on the Title VII pregnancy-discrimination claim and the parallel Ohio statutory discrimination claim, and remanded for trial.
- It affirmed summary judgment for defendants on breach of contract because the one-year contract was performed and did not guarantee renewal.
- It affirmed summary judgment on promissory estoppel because Cline failed to show a definite promise of renewal and detrimental reliance.

## Legal Principles

- Under *McDonnell Douglas*, the prima facie burden in discrimination cases is not onerous; courts should not fold the employer’s asserted nondiscriminatory justification into the prima facie analysis.
- A plaintiff can create a triable issue of pretext by showing the employer’s stated reason is weak, inconsistently applied, or selectively enforced in a way that disadvantages a protected class.
- Enforcement of a morality rule based solely on visible pregnancy, without comparable enforcement mechanisms for male employees, can support an inference of pregnancy-based sex discrimination sufficient to reach a jury.
- Under Ohio contract law, nonrenewal of a one-year employment contract generally is not a breach when the contract contains no express or implied right to renewal and has been fully performed.
- Promissory estoppel under Ohio law requires a promise and detrimental reliance; generalized expectations of renewal without evidence of reliance are insufficient.

## Conclusion

The Sixth Circuit held that Cline presented enough evidence for a jury to decide whether the asserted premarital-sex rationale was a pretext for pregnancy discrimination, but it rejected her contract-based theories because her one-year contract was completed and she showed no actionable promise of renewal or detrimental reliance.


Cline v. Catholic Diocese of Toledo, 206 F.3d 651 (6th Cir. 2000)