Marshall Turman v. The Abyssinian Baptist Church

Background

On March 5, 2024, the court postponed the initial pretrial conference until further order. On April 19, 2024, the defendants moved to dismiss the amended complaint and also asked the court to stay discovery while that motion was pending. The plaintiff opposed the discovery stay.

Court’s Analysis

The court explained that discovery may be paused for good cause while a motion to dismiss is pending. Relevant considerations include the amount and burden of the requested discovery and the strength of the dismissal motion.

The court reviewed the underlying motion but expressly made no ruling on it. The court found that the motion presented substantial arguments for dismissal. It also noted that the defendants’ main argument involved the ministerial exception, a legal doctrine that can prevent employment laws from being applied to certain claims involving a religious institution and its ministers. The court said that this argument supported pausing discovery because it involved a principle of avoiding judicial interference with religious institutions.

The court further found that discovery into the hiring process at issue in the plaintiff’s claims was likely to be extensive. The amended complaint alleged that the defendants created a 27-member committee at least partly to ensure that the selected candidate was male. The court also noted that the plaintiff had identified no prejudice from delaying discovery.

Ruling and Effect

The court granted the defendants’ request to stay discovery pending resolution of their motion to dismiss. The parties could exchange discovery informally to try to resolve the case, but no party was required to respond to a discovery request pending further order. The initial pretrial conference and the requirement to submit pre-conference materials also remained postponed pending further order. The order did not decide the motion to dismiss.