Dodson v. Lutheran Village - Affirmation of Summary Judgment Ruling
Summary
The Fourth Circuit Court of Appeals affirmed a lower court's ruling in Dodson v. Lutheran Village, granting summary judgment to the defendant on claims of religious discrimination and failure to accommodate. The unpublished opinion means the ruling does not set precedent.
What changed
The Fourth Circuit Court of Appeals has affirmed a district court's decision in Cara Elizabeth Liberto Dodson v. The Lutheran Village at Millers Grant, Inc. The appellate court found no reversible error in the magistrate judge's order granting summary judgment to the defendant on claims of religious discrimination and failure to accommodate, brought under Title VII of the Civil Rights Act of 1964. The court also affirmed the denial of the plaintiff's motion to produce evidence and modify the scheduling order. The case number is 1:23-cv-00169-EA.
This decision is an unpublished opinion and therefore does not constitute binding precedent in the Fourth Circuit. For regulated entities, this means the specific outcome of this case does not establish new legal requirements or interpretations. However, it reinforces the existing legal framework for religious discrimination and accommodation claims under Title VII. Employers should continue to ensure compliance with Title VII by having clear policies and procedures for handling religious accommodation requests and by ensuring that employment decisions are free from discriminatory bias.
Source document (simplified)
UNPUBLISHED UNITED STATES CO URT OF APPEALS FOR THE FOURTH C IRCUIT No. 25-1696 CARA ELIZABETH L IBERTO DODSON, Plaintiff - Appellant, v. THE LUTHERAN VI LLAGE AT MILL ERS GRANT, INC., Defendant - Appellee. Appeal from the Unite d States District Court for the District of Maryland, at Baltimore. Erin Aslan, Magistrate Judge. (1:23- cv -00169 -EA) Submitted: February 2 6, 2026 Decided: March 2, 2026 Before NIEMEYER and QUATTLE BAUM, Circuit Judge s, and FLOYD, Senior Circui t Judge. Affirmed by unpublish ed per curiam opini on. ON BRIEF: Terrell N. Roberts, III, ROBE RTS & WOOD, River dale, Maryland, for Appellant. Ralph L. Arnsdorf, Scott H. Ph illips, Patrick M. Wachter, FRANKLI N & PROKOPIK, P.C., Balt imore, Maryland, for A ppellee. Unpublished opinions are not binding prec edent in this circuit.
2 PER CURIAM: Cara Elizabeth Liberto Dodson appeals the magistrate judge’s * order granting Defendant summary judgment on Li berto Dodson’s religious discr imination and f ailure - to-accommodate claims, broug ht pursuant to Title VII of the Civil Rights Ac t of 1964, 42 U.S.C. §§ 2000e to 20 00e -17, and denying her “Motion f or Leave t o Produce Evidence Essential t o Justify Op position to a Motion f or Summary Ju dgment and t o Modify the Scheduling Order.” We have reviewe d the record and f ind no reversible err or. Accordingly, we affirm the magistrate judge’s order. Liberto Dodson v. The L utheran Vill. at Millers Grant, I nc., No. 1:23- cv -00169-EA (D. Md. May 2 2, 2025). We dispense with oral argument because the facts and legal contentions are ad equately presented in the materials before this co urt and argument w ould not aid the decisi onal process. AFFIRMED * The parties consented to the exercise of j urisdiction by the ma gistrate judge pursuant to 28 U.S.C. § 636(c).
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