Overview

• The 7th Circuit reversed summary judgment for Brownsburg Community School Corporation and ordered a jury trial on John Kluge’s refusal-to-accommodate claim under Title VII.
• A 2–1 panel majority led by Judge Michael Brennan found that conflicting evidence about student complaints and classroom disruption precludes deciding the case without juror evaluation.
• Under the Supreme Court’s Groff v. DeJoy framework, jurors must assess whether allowing Kluge to address students by last names only would impose an undue hardship on the district.
• The court also held that the sincerity of Kluge’s religious objections must be determined by a jury before any duty to accommodate arises.
• Judge Ilana Rovner dissented, warning that inviting juries into such workplace decisions risks turning courts into a ‘super-personnel department.’