MacDonald
MacDonald v. Grace Church Seattle
Opinion
Opinion
Thompson, J.
Plaintiff-Appellant Suzanne MacDonald (MacDonald) appeals the district court’s dismissal of her Title VII claims against the defendant nonprofit religious organizations for sexual harassment and retaliation because she failed to file her charges with the Equal Employment Opportunity Commission (EEOC) within 180 days of the last alleged discriminatory act. She asserts that the longer 300-day filing deadline (with which she complied) applies because the Washington State Human Rights Commission (Washington Commission) had subject matter jurisdiction over her charges. She argues that even though the Washington Law Against Discrimination exempts nonprofit religious organizations from the definition of “employer,” the Washington Commission had subject matter jurisdiction because it is designated as a Fair Employment Practice (FEP) agency by the EEOC. She also contends that the Washington Commission had subject matter jurisdiction because the Washington Law Against Discrimination contains provisions that prohibit sex discrimination and retaliation by parties other than “employers.”
MacDonald further argues, for the first time on appeal, that the exemption of nonprofit religious…