Kluge v. Brownsburg Community School Corp.
(U.S. Court of Appeals, 7th Cir., Apr. 7, 2023): Kluge, a teacher, brought a Title VII religious discrimination and retaliation action against Brownsburg Community School Corporation after being fired for refusing to refer to transgender students by their names as registered in the school’s official database. Kluge alleged that the names were not consistent with the transgender students’ sex recorded at birth and that using those names would infringe upon his religious beliefs. The school initially implemented an accommodation allowing Kluge to call the transgender students by their last names. This accommodation was later rescinded when it was determined that the practice was harming students and negatively impacting the learning environment for transgender students and the school in general. A federal district court rejected Kluge’s retaliation claim, reasoning that the school was not required to accommodate Kluge’s religious beliefs because doing so would impose an undue hardship on Brownsburg’s ability to meet its educational mission. The Seventh Circuit affirmed, reasoning that “Kluge’s accommodation harmed students and disrupted the learning environment.” Read the full decision here.