## Facts

- Christa Dias worked as a computer-technology coordinator at two Catholic elementary schools associated with the Archdiocese of Cincinnati.
- Dias’s employment contract contained a morals clause requiring employees to comply with the Roman Catholic Church’s philosophy and teachings.
- Dias was in a same-sex relationship and kept it private because she understood it would violate the morals clause.
- Dias became pregnant through artificial insemination and informed a school principal, Jennifer O’Brien, that she was pregnant.
- O’Brien told Dias she would be terminated because she was pregnant and unmarried.
- Dias responded that she did not become pregnant through premarital sex; she became pregnant through artificial insemination.
- O’Brien stated Dias would still be terminated because artificial insemination also violated the morals clause.
- Dias was terminated and sued, asserting pregnancy discrimination under federal and Ohio law and breach of contract (termination without good cause).
- Defendants argued (among other things) that the First Amendment’s ministerial exception barred the discrimination claims, that the morals clause defeated the contract claim, and that the Archdiocese was not Dias’s employer.
- After discovery, both sides filed cross-motions for summary judgment.

## Issues

1. Whether Dias’s role as a computer-technology coordinator at Catholic schools made her a “ministerial” employee such that the First Amendment barred her pregnancy-discrimination claims.
2. Whether genuine disputes of material fact about Defendants’ motivation (morals-clause enforcement versus pregnancy-based discrimination) prevented summary judgment on Dias’s statutory discrimination claims.
3. Whether the morals clause supplied contractual cause for termination as a matter of law, defeating Dias’s breach-of-contract claim.
4. Whether the Archdiocese could remain as a defendant under an integrated-employer theory based on evidence of control and interrelated operations.

## Decision

- The court held the ministerial exception did not apply because Dias’s job duties were technological and secular rather than ministerial or religious in function.
- The court denied summary judgment on the federal and Ohio pregnancy-discrimination claims, concluding that a reasonable jury could find that pregnancy (not solely a morals-clause violation) motivated the termination, and that intent questions required a trial.
- The court granted Defendants summary judgment on Dias’s breach-of-contract claim, finding the undisputed record established contractual cause to terminate under the morals clause.
- The court denied Dias’s motion for partial summary judgment.
- The court denied Defendants’ request for summary judgment dismissing the Archdiocese as an improper defendant, finding a triable fact dispute under the integrated-employer analysis.

## Legal Principles

- The ministerial exception is function-focused; employment by a religious institution and a general morals clause do not automatically convert a lay position into a ministerial one.
- Under summary-judgment standards in employment discrimination cases, when motive and intent are disputed and the record permits competing inferences, those questions are for the jury.
- An employer’s reliance on a morals clause may be a stated justification for discharge, but it does not by itself resolve statutory discrimination claims when the evidence permits a finding that pregnancy-based considerations also played a role.
- A breach-of-contract claim alleging termination “without cause” can fail as a matter of law when the contract language and undisputed conduct establish contractual cause for discharge.
- Integrated-employer liability can turn on fact questions about interrelated operations and centralized control of labor relations; where the record supports competing conclusions, summary judgment is improper.

## Conclusion

In *Dias v. Archdiocese of Cincinnati*, the court ruled on cross-motions for summary judgment and held that a lay computer-technology coordinator was not a ministerial employee, so the First Amendment did not bar her pregnancy-discrimination claims; because the evidence created a jury question about whether Defendants’ morals-clause rationale masked pregnancy-based discrimination, the statutory claims proceeded, but the court dismissed Dias’s breach-of-contract claim because the morals clause provided contractual cause for termination, and it left the Archdiocese in the case due to a factual dispute over whether it functioned as an integrated employer.


Dias v. Archdiocese of Cincinnati, 2013 WL 360355 (2013)