Court finds no racial discrimination against employee by Billy Graham organization

In McCallum v. Billy Graham Evangelistic Association(WD NC, Oct. 5, 2012), a North Carolina federal district court dismissed a Title VII racial discrimination claim that was brought by a former administrative assistant whose job was eliminated by the Billy Graham Evangelistic Association.  Plaintiff, Kimberly McCallum, was the only African American employed in BGEA’s executive offices.  She claims that her loss of her job was triggered by her complaining that BGEA was biased against African-American churches. In a previous decision in the case, the court concluded that the ministerial exception doctrine did not apply because McCallum’s duties were not part of the spiritual and pastoral mission of the church and did not involve church governance. Now the court also concluded that the suit is not barred by the church autonomy doctrine because “religion plays a minimal to non-existent role” in the discrimination claim.  However the court granted summary judgment to defendants because “a jury could not reasonably find or infer that discrimination was a motivating factor in any of the challenged employment decisions of BGEA.”