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Rohland v. St. Cloud Christian School

12/21/2004



In this appeal from a partial judgment granting respondent summary judgment on appellant's disability-discrimination claim, appellant argues that the district court erred by concluding that appellant did not establish a genuine issue of material fact about whether she is disabled. By notice of review, respondent argues that the district court lacked subject-matter jurisdiction to consider appellant's claims because judicial review violates its rights under the First Amendment to the United States Constitution and the freedom-of-conscience clause of the Minnesota constitution. Respondent also challenges the denial of its motion for summary judgment on appellant's age-discrimination claim. We affirm in part and dismiss the appeal in part.


FACTS


Appellant Ruth Rohland, who has diabetes, was employed by respondent St. Cloud Christian School, a nondenominational Christian school, as a third-grade teacher from 1988 to 2001. Under their contract, teachers at the school acknowledge that they are born-again Christians, are active church members, and are committed to Christian education and view it as a ministry and a calling from the Lord.


Appellant received positive employment-performance reviews on November 19, 1999, and May 1, 2000. However, in the 1999-2000 school year, difficulties arose when appellant agreed to take a larger class than usual and had a difficult student. A classroom assistant for appellant observed that appellant became harsher with the children, except when other adults were present. She also observed appellant acting in an impatient and derogatory manner with the children.


On May 20, 2000, after parents complained, a meeting was held that became explosive and polarized the parents. As a result, one parent removed his children from the school. At about this time, when parents of second-graders began requesting teachers for the next school year, more than half asked that their child not be assigned to appellant's class. Also during this school year, appellant broke her foot and was on workers' compensation leave from March 9 to 20, 2000.


On August 24, 2000, respondent sent a letter to appellant that essentially placed her on probation. The letter stated:


In light of the difficulties that occurred at the end of the 1999-2000 school year, we felt the need to both reassure you of our support, as well as clarify our expectations.


All [St. Cloud Christian School] teachers, at the time they sign their contracts, agree to uphold the spiritual and professional qualifications listed. During the 1999-2000 year, the mode of discipline, and on many days, your general demeanor with the children was observed by Mrs. Froemming [the school principal] as well as parents, students, and other staff, to not be in keeping with the expected conduct of a Christian teacher. This could be summarized by saying that you were using words, tone of voice and methods of correction that were degrading to the students. This was discussed with you in the Spring, and you admitted that this was an area that you were struggling with. You also indicated, when asked by Mrs. Froemming, that you had fallen out of regular personal Bible study and church attendance.


We would also indicate to you at this time that it is the expectation of the school to have its teachers present whenever possible. Your request for extra days off in March of last year was over the allotted 3 days of personal time as indicated by your contract. While we understand that some circumstances arise on occasion, it is very important to parents and students that all SCCS teachers be in attendance for as many days as is possible.


We have done o

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