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It is well-established that the central question in any employment-discrimination case is whether an employer would have taken the same action had the employee been of a different race (age, sex, religion, national origin, etc.) and everything else had remained the same.
General Motors’ Affinity Group program resulted from efforts to make diverse constituencies feel more welcomed and valued, to remove barriers to productivity for all employees, and to increase market share and customer enthusiasm in diverse market segments. General Motors's Affinity Group Guidelines prohibited the conferral of Affinity Group status on any group promoting or advocating a religious position. Citing these Guidelines, General Motors declined to grant Affinity Group status to employee John Moranski's proposed Christian Employee Network. Moranski filed a complaint with the Equal Employment Opportunity Commission and received a Notification of Right to Sue letter. He then filed suit in federal court, alleging that General Motors discriminated against him on the basis of his religion when it denied his request for Affinity Group recognition. The district court granted General Motors's motion to dismiss for failure to state a claim upon which relief could be granted, and Moranski appealed, contending that the decision not to sanction any group that promoted a religious position constituted unlawful discrimination against him on the basis of his Christian religion, in violation of Title VII.
By declining to grant Affinity Group status to the employee’s proposed Christian Employee Network, did the employer discriminate against the employee on the basis of his Christian religion, in violation of Title VII?
The allegations in the Moranski’s complaint made it clear that General Motors would have taken the same action had Moranski possessed a different religious position. In addition, General Motors had never recognized an affinity group that promoted or advocated any religious position, even one of religious indifference or opposition to religion. General Motors’s decision to treat all religious positions alike in its affinity group program did not constitute impermissible discrimination under Title VII. Accordingly, the court affirmed the district court’s judgment.