John Kluge was an orchestra teacher at Brownsburg High School, a public school in Indiana, who resigned after a dispute with his school district over how he addressed transgender students in his classroom. The controversy arose in 2017 after the School adopted a policy requiring teachers to use students’ names and pronouns as listed in the School’s PowerSchool database. This included updates to accommodate transgender students who provided parental and medical authorization for a name and gender change. Kluge, a Christian, objected on religious grounds, believing that affirming a student’s gender identity conflicted with his religious convictions. He requested an accommodation allowing him to use students’ last names only, which the School initially approved for the 2017-18 academic year.
As the year progressed, students, parents, and faculty raised concerns. Transgender students in Kluge’s class reported feeling alienated, dehumanized, and targeted. They asserted that his refusal to use their names undermined their identities and singled them out. Faculty members shared concerns with School leaders that the practice caused discomfort and disrupted the classroom environment. Two students submitted complaints, and others shared that Kluge’s practice drew attention to transgender students, making them feel excluded. At the same time, some witnesses—including students and a co-teacher—stated they did not observe any disruption or discriminatory behavior from Kluge. Following the complaints, administrators reevaluated Kluge’s accommodation and concluded that the last-name-only practice was untenable.
In early 2018, the School rescinded Kluge’s accommodation and told him he must comply with the name policy or face termination. Kluge submitted a resignation letter, which he later sought to rescind. The School declined to allow his return and posted his position as vacant. Kluge filed suit under Title VII of the Civil Rights Act of 1964, alleging religious discrimination and retaliation. He claimed the School failed to accommodate his religious beliefs and retaliated against him for exercising his religious rights.
The trial court initially granted summary judgment to the School, finding that allowing Kluge to use last names only imposed an “undue hardship” on its mission to provide a safe and inclusive environment. The trial court also found that Kluge’s actions risked exposing the School to Title IX liability for discrimination against transgender students.
While the case was pending appeal, the Supreme Court decided Groff v. DeJoy, which clarified the Title VII standard for undue hardship in religious accommodation cases. Under Groff, an employer must show that an accommodation would impose a substantial burden on the business’s conduct, not merely a “de minimis” cost. Applying Groff, the Seventh Circuit reversed the trial court’s summary judgment ruling and reinstated Kluge’s claim.
The Court of Appeals held that there were genuine disputes of material fact about whether allowing Kluge to use last names only caused undue hardship. It found conflicting evidence about whether students were harmed or if the learning environment was meaningfully disrupted. Some evidence suggested that students understood the practice and felt stigmatized, while others said they saw no issues. The Court also found factual disputes about whether the School’s risk of Title IX liability was significant, emphasizing that Kluge had applied his policy uniformly and that there was no clear evidence of Kluge treating transgender students differently.
Importantly, the Court distinguished the standard for religious accommodation claims from other types of discrimination claims under Title VII. Under Groff, the employer’s good faith belief in hardship is not enough; it has to objectively demonstrate that the accommodation itself causes substantial disruption or cost. The Court declined to defer to the School’s judgment without further fact-finding and remanded the case for trial.
The Court also upheld the trial court’s decision to deny Kluge’s motion for summary judgment on the question of his religious sincerity, citing factual disputes about whether he consistently adhered to the last-name-only accommodation or selectively applied it. The School had presented evidence suggesting that Kluge occasionally used first names, particularly when communicating with students who were not transgender, which it argued undermined the sincerity of his claimed religious belief. Because Title VII requires that a religious belief be sincerely held to trigger accommodation obligations, and because the evidence raised a credibility issue, the Court found that the matter should be resolved by a jury.
The Court also affirmed summary judgment for the School on Kluge’s retaliation claim, finding no evidence of pretext behind the School’s decision to end the accommodation. It reasoned that the repeated complaints from parents and teachers about the last-name only accommodation was a legitimate non-discriminatory action that led to the School’s decision to rescind the accommodation.
Kluge v. Brownsburg Cmty. Sch. Corp. (7th Cir. Aug. 5, 2025) ___ F.4th ___, 2025 U.S. App. LEXIS 21012.
Note: LCW covered this case previously. This case underscores the complexities of religious accommodations in school settings, particularly where such accommodations may affect the rights or well-being of students. The Court’s application of Groff illustrates the high bar employers must meet to show undue hardship when assessing the viability of religious accommodations.