Rohrbacher v. Teton Therapy

Rohrbacher v. Teton Therapy PC, Docket No. 1:18-cv-00214 (D. Wyo.
Dec 17, 2018), Court Docket - 1 Entry
Current on Bloomberg Law as of Dec. 17, 2018 17:13:09

U.S. District Court
District of Wyoming (Casper)
CIVIL DOCKET FOR CASE #: 1:18-cv-00214-MLC
Rohrbacher v. Teton Therapy PC

Date Filed: Dec 17, 2018
Nature of suit: 442 Civil Rights: Jobs
Assigned to: Honorable Mark L Carman
Cause: 42:2000e Job Discrimination (Employment)
Jurisdiction: Federal Question
Jury demand: Plaintiff
Parties and Attorneys
Plaintiff Julie Rohrbacher
Representation Katherine A Strike

Stanbury & Strike, PC
329 Main Street
PO Box 1630
Lander, WY 82520
(307) 332-5000
Fax: (307) 332-5001
kstrike@stanbury-strike.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Defendant Teton Therapy PC

a Wyoming corporation
Docket Entries
Numbers shown are court assigned numbers.

Entry # Filing Date Description
1 Dec 17, 2018 COMPLAINT (1 summons(es) issued) with Jury Demand ( Filing fee $400 receipt
#CAS002163.), filed by Julie Rohrbacher. (Attachments: # 1 Civil Cover Sheet, # 2 Consent to
Magistrate Judge) (Court Staff, scat) (Entered: 12/17/2018)
© 2018 The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service
// PAGE 1
This page has been intentionally left blank
COMPLAINT (1 summons(es) issued) with Jury Demand ( Filing fee $400 receipt #CAS002163.),
Multiple Documents
Part Description
1 15 pages
2 Civil Cover Sheet
3 Consent to Magistrate Judge
© 2018 The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service
// PAGE 1
Case 1:18-cv-00214-MLC Document 1 Filed 12/17/18 Page 1 of 15
U S DISTRICT COURT
Katherine A. Strike, WSB # 6-4284 DiSTri.Ci Gr WrOHfKa
STANBURY & STRIKE,PC on,„ .
PO Box 1630 25f80EC 17 PM 1:58
Lander, WY 82520 err-3« • ■.....
(307) 332-5000 C
(307) 332-5001 FAX
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF WYOMING
JULIE L. ROHRBACHER
An individual.
Civil Action No. / ^ ' C(/-^
Plaintiff.
vs.
TETON THERAPY, P.C.

A Wyoming Corporation,
Defendant.
COMPLAINT AND REQUEST FOR JURY TRIAL
COMES NOW Plaintiff, Julie L. Rohrbacher, by and through her attorney, Katherine
Strike, Stanbury & Strike, PC, hereby asserts the following allegations and claims against the
Defendant, Teton Therapy, P.C.
This is an employment discrimination and harassment case arising from Teton
Therapy's discriminatory treatment of Ms. Rohrbacher, a former employee, based on religion.
Teton Therapy discriminated against Ms. Rohrbacher, a Non-Scientologist, by subjecting her
to: (a) a hostile work environment based on religion by Teton Therapy's imwelcome
Rohrbacher v. Teton Therapy, PC

Complaint and Request for Jury Trial
Page 1
imposition upon her of Scientology religious practices, teachings, beliefs, training, and
principles; and (b) disparate treatment based on religion when Teton Therapy coerced her to
engage in a range of Scientology religious practices and training as a mandatory condition of
employment.
This action assets violations of Title VII of the Civil Rights Act of 1964 [Title VII], as
amended^ 42 U.S.C. § 200pe, et. seq.
I. PARTIES
1. Ms. Rohrbacher, a female, is a United States citizen and resident of the State of
Wyoming.
2. At all times in issue, Ms. Rohrbacher resided and worked in the Judicial District of
the Court.
3. Teton Therapy, P.C., is a corporation registered and incorporated in the State of
Wyoming.
4. Defendant provides physical and occupational therapy services.
5. Jeff McMenamy is the Owner and Chief Executive Officer of Defendant.
6. Defendant conducts business in the towns of Riverton, Lander, Cheyenne, and
Sheridan, in the State of Wyoming.
7. Ms. Rohrbacher was employed by Defendant from on or about November 30, 2011,
to on or about May 24,2013.
8. Defendant forced Ms. Rohrbacher to resign and/or constructively discharged Ms.
Rohrbacher from employment on or about May 24,2013.

Page 2
II. JURISDICTION AND VENUE
9. Jurisdiction is asserted pursuant to Title VII,42 U.S.C. §§ 2000e,2000e-5, and
2000e-5(f)(l)(3), as amended, the Civil Rights Act of 1991,42 U.S.C. § 1981a(a)(1),(b)(1)-
(4),(c),(d)(1)(2).
10. Ms. Rohrbacher, a Non-Scientologist, is a member ofa Title VII protected class.
11. At all times in issue, Ms. Rohrbacher was qualified to perform the duties of her
position.
12. At all times in issue. Defendant was an "employer" within the meaning of the Title
Vn.42 U.S.C. § 2000e(b),(g), and (h).
13. Pursuant to 28 U.S.C. § 1391(b)(c), venue is proper in this Court because the events
and claims arose in the town of Lander, State of Wyoming,in the Judicial District ofthis Court.
III. ADMINISTRATIVE PROCEDURES
14. Prior to filing this action, Ms. Rohrbacher timely, properly, and lawfully exhausted
all required administrative prerequisites, procedures, and remedies.
15. Ms. Rohrbacher filed a timely and proper charge of discrimination based on
religion, under Title VII of the Civil Rights Act of 1964, as amended^ and the Wyoming Fair
Employment Practice Act of 1965, as amended.
16. Ms. Rohrbacher's charge of discrimination was jointly filed with the Wyoming
Department of Workforce Services Fair Employment Program [WFEP Charge # 128-2013] and
the Equal Employment Opportunity Commission [EEOC]. [EEOC Charge # No. 32K-2013-
00146].

Page 3
17. On September 18, 2018, the EEOC issued a Notice of Right to Sue letter to Ms.
Rohrbacher.
18. This civil action is timely and properly filed because it is filed within 90 days of the
date ofthe EEOC Notice of Right to Sue letter.
IV. GENERAL ALLEGATIONS
19. Ms. Rohrbacher, a female, is forty-six years of age.
20. On or about November 30,2011, Ms. Rohrbacher was hired by Defendant.
21. Ms. Rohrbacher worked as a receptionist and office assistant for Defendant at its
facility in Lander, Wyoming.
22. The Church of Scientology is a religion developed by L. Ron Hubbard.
23. At all times in issue, Defendant's management acted through conduct by
McMenamy,and/or conduct taken at the direction of McMenamy.
24. Based on the conduct of McMenamy and the conduct of Defendant, as alleged
herein. Plaintiffreasonably believes McMenamy is a practicing Scientologist.
25. Defendant required Ms. Rohrbacher, in the course of her employment, to
participate in, and be subjected to religious practices, teachings, beliefs, training, and principles
of Scientology.
26. Defendant, throughout Ms. Rohrbacher's employment, subjected her to
mandatorv terms and conditions of employment based on religious practices, teachings, beliefs,
training, and principles of Scientology.

Page 4
27. Defendant's mandatory, Scientology-based, terms of employment, included but
were not limited to requiring Ms. Rohrbacher to:(a) be subjected to management's preaching
of Scientology practice and principles; (b) take and complete an employment orientation,
training, and communication course entitled "Breaking the Code." [Code Course], which
included completing a Scientology workbook and learning Scientology terms; and (c) attend a
weeklong, management training Scientology-based seminar.
28. Ms. Rohrbacher found Defendant's conduct, in requiring her to participate in,
and be subjected to mandatory terms and conditions of employment based on Scientology
religious practices, teachings, beliefs, and training, to be unwelcome, offensive, intimidating,
and abusive.
29. Defendant inserted religion into the workplace and created a hostile work
environment for Non-Scientologists.
30. Defendant, as a mandatory term and condition of employment, required Ms.
Rohrbacher to take and complete the Code Course.
31. Defendant explicitly conditioned a salary raise for Ms. Rohrbacher on her
completion ofthe Code Course.
32. Ms. Rohrbacher, because of her need to remain employed, began the Code
Course but could not finish the course because: (a) she objects to the teachings of
Scientology; (b) she objected to the Defendant requiring her to take a course in
Scientology; and (c) she found the Defendant's condition of employment and directive that
she take and complete the course imwelcome,intimidating, offensive, and abusive.

Page 5
33. Ms. Rohrbacher voiced her objections/complamts to the Defendant required
concerning being required to participate in, and be subjected to religious practices, teachings,
beliefs, training, and principles of Scientology, including mandatory terms and conditions of
employment based on religious practices, teachings, beliefs, training, and principles of
Scientology.
34. Ms. Rohrbacher's Objections/complaints to Defendant concerning Scientology
practices/requirements included but were not limited to; (a) Defendant subjecting her to
Scientology religious teachings, beliefs, training, etc.;(b) the Code course was written by
L. Ron Hubbard; (c) Defendant was forcing her to learn Scientology teachings and
principles; and(d)the training was based on Scientology.
35. The Core Course uses concepts and communication terms directly taken from
teaching, practices, and beliefs of Scientology.
36. The stated purpose of the Code Course is to teach principles directly
emanating from L. Ron Hubbard,the founder of Scientology.
37. The Code Course training uses terms directly associated with L. Ron
Hubbard.
38. The Code Course teaches principles directly taken from the practices,
teachings, principles, and beliefs of Scientology.
39. The Core Course uses concepts and communication terms directly taken from
the practices, teachings, principles, and beliefs of Scientology, including but limited to:
(a) The A-R-C Triangle,
(b) High affinity.
Rohrbacher v. Teton Therapy,PC

Page 6
(c) Low affinity,
(d) Reality (area of agreement),
(e)No reality(no area of agreement),
(f) Balanced inflowing/outflowing communication,
(g)The K-R-C Triangle,
(8)Command line,
(h)Backflashing,
(i) Product and value,
(j) Condition ofnon-existence,
(k)Emergency condition,
(1) Battle plan, program and strategic plan,
(m)Completed staff work (often abbreviated as dev-t),
(n)Developed traffic,
(o)Up- statistics(and down statistics),
(p)Ethics reports,
(q)Entheta,
(r)Enturbulate,
(s)201Confronting,
(t) Off-origin,
(u)Channel skip,
(v)Hat, and
(w)Non-compliance.

Page 7
40. The terms used in the Code Course have specific meanings and those
meaning are unique to their use in Scientology. The terms, as defined by L. Ron Hubbard,
are not part ofthe common vernacular.
41. The combination ofterms in the Code Course is unique to Scientology.
42. On or about April of 2013, Defendant posted/advertised for the position of
Manager at Defendant's Lander Clinic.[Manager position].
43. In April of 2013, Ms. Rohrbacher effectively applied for promotion to the
Manager position.
44. Ms. Rohrbacher was qualified to serve in the Manger position.
45. Defendant informed Ms. Rohrbacher that she needed to retake and the complete
the Code Course prior to selection for the Manager position.
46. In the course of her application for the Manager position. Defendant informed
Ms. Rohrbacher that she needed to take a weeklong, Scientology-based management course,
which Defendant's managers complete.
47. The management course was in the Clearwater, Florida, at or near the location
of the Flag Land Base of the Church of Scientology, which is advertised as an important
spiritual headquarters.
48. Defendant directed Ms. Rohrbacher to consult with a Scientology life- coach.
49. Ms. Rohrbacher refused to:(a)retake and complete the Code Course;(b) attend
and complete the weeklong, Scientology-based management course in Clearwater, Florida; and
(c)consult with a Scientology life-coach.

Page 8
50. Defendant informed Ms. Rohrbacher that she was an unsuccessful applicant for
the Manager position.
51. In May of 2013, Ms. Rohrbacher informed Defendant she was uncomfortable
with the Scientology process/practice/concept of termination and the techniques and teachings
of the Code Course, and that she did not want to retake and complete the Code Course or
Scientology-based communication courses, and/or consult with Scientology-based coach.
52. Defendant, in response to Ms. Rohrbacher refusals to engage in Scientology-
based practices, teachings, and training directed her to quit and take two week's severance pay
or she would be fired.
53. Defendant forced Ms. Rohrbacher to involuntarily resign from employment.
54. Defendant constructively discharged Ms. Rohrbacher by creating an intolerable
working environment, based on the totality of conditions and discriminatory animus,terms, and
working environment, that would have compelled a reasonable person in Ms. Rohrbacher
position to resign.
55. Based on the above factors and conditions, Ms. Rohrbacher resigned from
employment.
56. Defendant's discrimination against Ms. Rohrbacher includes discrimination
based on her failure to conform to Defendant's Scientology religious practices, beliefs, training,
and principles.
57. Defendant 's discriminatory treatment of Ms. Rohrbacher was intentional,
willful, and/or and in reckless disregard of her right to be from religious discrimination under
Title VII.

Page 9
FIRST CLAIM
[Religious Harassment- Hostile Work Environment]
58. Title VII prohibits religious harassment in the form of a hostile work
environment, based on religion. 42 U.S.C. Sections 2000e-2(a)(1).
59. Defendant, in consideration of all the facts, in a cumulative manner,
intentionally created, tolerated, and perpetuated a hostile work environment, based upon
religion, against Ms. Rohrbacher.
60. The Defendant's conduct created a workplace that was permeated with
discriminatory intimidation and insult, sufficiently severe and pervasive as to adversely alter
the terms, conditions, and privileges of Ms. Rohrbacher's employment and create an abusive
working environment for Ms. Rohrbacher.
61. The Defendant's actions constitute discrimination against Ms. Rohrbacher based
on religion.
62. The cumulative adverse conduct to which Ms. Rohrbacher was subjected was:(a)
continuous; (b) severe; (c) humiliating; (d) repeated; and (e) emotionally threatening and
harmful.
63. The Defendant's hostile work environment included but was not limited to the
following tangible employment actions:(a)denying Ms. Rohrbacher promotion to the Manager
position; and (b) forcing the involuntary resignation of Ms. Rohrabacher from employment
and/or the constructively discharging Ms. Rohrabacher from employment.
64. The hostile work environment to which Ms. Rohrbacher was subjected was
created and perpetuated by McMenamy, a person in the management/owner level of Defendant,

Page 10
possessing substantial authority over the terms and conditions of Ms. Rohrbacher's employment,
and/or by persons working pursuant to the direction of McMenamy.
65. The Defendant created and perpetuated and knew or should have known of the
cumulative conduct to which Ms. Rohrbacher was subjected and Defendant: (a) failed to
implement reasonably prompt, and appropriate corrective action concerning the cumulative,
unlawful conduct to which Ms. Rohrbacher was subjected; and (b) failed to respond reasonably
to the hostile work environment based on religion.
66. Each successive episode of the Defendant's cumulative and total conduct set forth
in this Complaint, and constituting the hostile work environment confronted by Ms. Rohrbacher,
had its predecessors, and the impact ofthe separate incidents accumulated such that the unlawful
work environment created, exceeded the sum of any individual episode.
67. The Defendant's conduct directly caused Ms. Rohrbacher to suffer severe mental
and emotional distress and economic losses.
68. Ms. Rohrbacher, as a Non-Scientologist, was specifically targeted and harmed by
the Defendant's cumulative conduct, which exposed Ms. Rohrbacher, a Non-Scientologist, to
disadvantageous terms and conditions of employment in the form of a hostile work environment
to which practicing Scientologists and/or Defendant's employees who participated in the
Defendant's Scientology practices and requirements, were not subjected.
69. The Defendant's adverse conduct against Ms. Rohrbacher was sufficiently severe
and pervasive to adversely alter the terms, conditions, and privileges of Ms. Rohrbacher's
employment and create an abusive working environment for Ms. Rohrbacher. Defendant, in a

Page 11
cumulative and continuing manner, created, tolerated, and perpetuated an unlawful and
unwelcome hostile work environment based on religion, for Ms. Rohrbacher.
70. Ms. Rohrbacher constitutes: (a) an intentional, unlawful, hostile work
environment, based on sex, in violation of42 U.S.C. Sections 2000e-2(a)(1)(2);(b)intentional
and willful unlawful discriminatory practices in violation of42 U.S.C. Section 1981a(a)(1),(b)
(2)(3),(d)(1)(2); and (c).
SECOND CLAIM
[Religious Discrimination in Violation of Title VII]
71. Ms. Rohrbacher hereby incorporates and restates all allegations previously
asserted in this Complaint as though fully incorporated herein.
72. Title VII prohibits the Defendant from discriminating against Ms. Rohrbacher:(a)
with respect to her compensation, terms, conditions, or privileges of employment, because of
religion sex; and/or (b) by limiting, segregating, or classifying her in any way, which would
deprive, or tend to deprive her of employment opportunities, or otherwise adversely affect her
status as an employee, because of religion.
73. Ms. Rohrbacher, a Non-Scientologist, is a member ofa protected Title VII class.
74. Defendant engaged in unlawful, direct, and intentional religious discrimination
against Ms. Rohrbacher because of her religion. 42 U.S.C. Sections 2000e-2(a)(l)(2).
75. As specifically described in the prior paragraphs of this Complaint, Defendant
discriminated against Ms. Rohrbacher:(a) with respect to her compensation, terms, conditions,
and privileges of employment because of her religion; and (b) by limiting, segregating, and

Page 12
classifying Ms. Rohrbacher in a manner which deprived or tended to deprive Ms. Rohrbacher of
employment opportunities, and adversely affected her status as employee, because of religion.
76. Defendant, intentionally subjected Ms. Rohrbacher to more adverse,
discriminatory, hostile, and retaliatory practices, concerning the terms and conditions of her
employment, than the way Defendant treated employees who were Scientologists and/or who
participated in Defendant's mandatory Scientology-based practices and training, and/or complied
with Defendant's mandatory Scientology-based terms and conditions of employment of their
employment.
77. Defendant's unlawful, intentional religious discrimination was created,
perpetrated, and/or tolerated by Defendant's owners and managers, all having specific
knowledge, or reason to know,ofthe discriminatory actions set forth herein.
78. Defendant's treatment of Ms. Rohrbacher constitutes; (a) intentional, unlawful
sexual discrimination, in violation of 42 U.S.C. Sections 2000e-2(a)(l)(2), and (b) intentional,
willful, unlawful discriminatory practices in violation of 42 U.S.C. Section 1981a (a)(1),
(b)(l)(2)(3)(D),and(d)(l)(2).
VI. REQUEST FOR RELIEF
WHEREFORE, Defendant's unlawful conduct directly caused Ms. Rohrbacher to suffer
injuries, damages, and losses;
FURTHER, Ms. Rohrbacher respectfully requests this Court to enter judgment in her
favor and against Defendant on the claims in issue and award the follovsdng relief under Title
VII, and all applicable laws:

Page 13
(a) To enter a judgment in favor of Ms. Rohrbacher and against Defendant, finding
the acts of the Defendant constitute unlawful intentional discrimination in violation of the Title
VIL
(b) To enter a judgment in favor of Ms. Rohrbacher and against Defendant, finding
the acts ofthe Defendant constitute a willful violation of Title VII.
(c) To award Ms. Rohrbacher the remedies of damages for back pay, front pay,
restored benefits, accommodations, actual monetary damages, loss of wages, salary, retirement
contributions, all loss ofincome, and all loss of monetary damages to which she is entitled.
(d) To award Ms. Rohrbacher compensatory damages for emotional pain, suffering,
inconvenience, mental anguish, loss of enjoyment of life, future pecuniary losses, and other non-
pecuniary losses, and all loss of compensatory damages to which she is entitled.
(e) To award Ms. Rohrbacher punitive damages.
(f) To award Ms. Rohrbacher attorney fees and costs.
(g) To award Ms. Rohrbacher pre-judgment and post-judgment interest at the
appropriate rate provided by law.
(h) To direct Defendant to take such affirmative relief steps as are necessary to ensure
that the effects of Defendant 's unlawful employment practices are eliminated and do not
continue to affect Ms. Rohrbacher's employment opportunities; and
(i) Order Defendant to reinstate Ms. Rohrbacher to employment or in lieu of
reinstatement, award Ms. Rohrbacher front pay.
(j) To award Ms. Rohrbacher all other legal and equitable relief, to which Ms.
Rohrbacher is entitled pursuant to any law, that this Court deems just, equitable, and proper.

Page 14
VIL JURY TRIAL REQUEST
Pursuant to Fed.R.Civ.P. 38 (a)(b)(c), Title VII, and all applicable laws providing for a
right to trial by jury, Ms. Rohrbacher requests a jury trial of all claims and issues in this action,
and herewith submits the requisite jury fee.
Dated: December 17^,2018.
Respectfully submitted this 17'*' day of December 2018.
Julie L. Rohrbacher,
Katherin^ WSB #16-4284

ST^ PC
PODrix 1630
Lander, WY 82520
(307)332-5000
(307)332-5001 FAX
Attorney for Plaintiff

Page 15
Case 1:18-cv-00214-MLC Document 1-1 Filed 12/17/18 Page 1 of 1
JS44 (Rev. 06/17)
CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither rÎace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided W local rules ofcourt. This form,approved by the Judicial Conference ofthe United States in September 1974, isrequned for the use ofthe Clerk of Court for the
purpose ofinitiating the civil docket sheet /SE£ INSTRUCTIONSON nextPAGE OF THISFORM.)
I.(a) PLAINTIFFS DEFENDANTS
JULIE L. ROHRBACHER,Plaintiff
fb) County of Residence of First Listed Plaintiff Fremont Countv. WY CounlvofResidenceofFirstListedDefendant

(EXCEPTINU.& PLAINTIFF CASES) (IN US PLAINTIFF CASES ONLY) d
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys(Firm Name, Address, and Telephone Number) Attorneys(IfKnown)

Katherine A. Strike, Stanbury & Strike, PC
PO 80X1630
Lander, WY 82520 (307) 332-5000
II. BASIS OF JURISDICTION(Placean "X"In One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES(P/oce on "X"ln one Boxfor plaintiff
(For Diversity Cases Only) and One Boxfor Defendant)
G 1 U.S. Government H 3 Federal Question FTP DEF PTF DEF
Plaintfff (U.& Government Nol a Party) Citizen ofThis State IX 1 G 1 Incorporated or Principal Place G 4 lX4
of Business In This State
G 2 U.S. Govenunent G 4 Diversity Citizen ofAnother State G 2 G 2 Incorporated 0/»f Principal Place G 5 OS
Defendant (Indicate Clllzenship ofParlies in Item III) of Business In Another State
Citizen or Subject ofa G 3 G 3 Foreign Nation 06 06

Foreian Coimtrv
Click here for: Natuig_oFMiLCgde_Dgscrjp^^

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
O 110 Insurance PERSONAL INJURY PERSONAL INJURY G 625 Drug Related Seizure G 422 Appeal 28 USC 158 G 375 False Gaims Act
□ 120 Marine O 310 Airplane O 365 Personal Injury - of Property 21 USC 881 G 423 Withdrawal 0 376QuiTam(31USC
O 130MiUerAct 0 315 Airplane Product Product LiabiUty G 690 Other 28 USC 157 3729(a))
□ 140 Negotiable Instnunent Liability a 367 Health Care/ G 400 State Reiqiportionment
0 150 Recoveiy of Overpayment O 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS G 410 Antitrust
& Enforcement of Judgment Slander Persona] Injuiy G 820 Copyrights G 430 Banks and Banking
O 151 Medicare Act O 330 Federal Empliêis' Product Liability G 830 Patent G 450 Commerce
0 152 Recoveiy of Defaulted Liability O 368 Asbestos Personal G 835 Patent • Abbreviated . G 460 Deportation
Student Loans O 340 Marine Injury Product New Drug Application G 470 Raêteer Influenced and
(Excludes Veterans) □ 345 Marine Product Liability G 840 Trademark Coirupt Organizations
O 153 Recoveiy of Overpayment Liability PERSONAL PROPERTY labor snriAi.sFrnRiTY G 480 Consumer Credit
of Veteran's Benefits O 350 Motor Vehicle O 370 Other Fraud G 710 Fair Labor Standards G 861 HIA (13951!) O 490 Cable/Sat TV
0 160 Stockholders' Suits 0 355 Motor Vehicle O 371 Truth in Lending Act G 862 Black Lung (923) G 850 Securities/Commodities/
O 190 Other Contract Product Liability G 380 Other Personal G 720 Labor/Management G 863 DIWC/DIWW (405(g)) Exchange
O 195 Contract Product Liability O 360 Other Personal Property Damage Relations O 864 SSID Title XVI G 890 Other Statutory Actions
O 196 Franchise Injury G 385 Property Damage G 740 Railway Labor Act G 865 RSI (405(8)) G 891 Agricultural Acts
O 362 Personal Injury - Pro^ct Liability G 751 Family and Medical G 893 Environmental Matters
Medical Malpractice Leave Act G 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTO PRISONER PEirnONS G 790 Other Labor Litigation FEDERAL TAX SUITS Act
O 210 Land Condemnation G 440 Other Civil Rights Habeas Corpus: G 791 Employee Retirement O 870 Taxes (U.S.Plaintifr G 896 Arbitration
G 220 Foreclosure G 441 Voting G 463 Alien Detainee Income Security Act or Defendant) G 899 Administrative Procedure
G 230 Rent Lease & Ejectment S 442 Employment G 510 Motions to Vacate O 871 IRS—Third PaiD- Act/Review or Appeal of
Agen^ Decision
G 240 Torts to Land 443 Housing/ Sentence 26 USC 7609
G 245 Tort Ih'oduct Liability Accommodations G 530 General O 950 Constitutionality of
0 290 All Other Real Property G 445 Amer. w/Disabilities' G 535 Death Penalty IMMIGRATION State Statutes
Employment Othen G 462 Naturalization Application
O 446 Amer. w/Disabilities' G 540 Mandamus & Other G 465 Other Immigration
Other G 550 Civil Rights Actions
G 448 Education G 555 Prison Condition
G 560 Civil Detainee-
Conditions of
Confinement
V. ORIGIN (Place an "X' In One Box Only)

1 Original □ 2 Removed from □ 3 Remanded from □ 4 Reinstated or □ 5 Transferred from O 6 Multidistrict □ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cllejuris/llctlonalstaluies unless diversity):
Title VII of the Civil Rights Act of 1964. as amended. 42 USC 2000e. et sea.
VI. CAUSE OF ACTION Brief description of cause:
Religious discrimination
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMANDS CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: H Yes ONo
VIII. RELATED CASE(S)

(See Instrucllons):
IF ANY JUDGE DOCKET NUMBER
DATE
FORQFnCE
RECEIPT# AMOUNT APPLYING IFP JUDGE MAG. JUDGE

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Rohrbacher v. Teton Therapy PC, Docket No. 1:18-cv-00214 (D. Wyo.

Dec 17, 2018), Court Docket - 1 Entry

Current on Bloomberg Law as of Dec. 17, 2018 17:13:09

Rohrbacher v. Teton Therapy PC

Parties and Attorneys

Plaintiff Julie Rohrbacher

Representation Katherine A Strike

Defendant Teton Therapy PC

Numbers shown are court assigned numbers.

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF WYOMING

TETON THERAPY, P.C.

COMPLAINT AND REQUEST FOR JURY TRIAL

Defendant, Teton Therapy, P.C.

This is an employment discrimination and harassment case arising from Teton

Therapy's discriminatory treatment of Ms. Rohrbacher, a former employee, based on religion.

Teton Therapy discriminated against Ms. Rohrbacher, a Non-Scientologist, by subjecting her

Rohrbacher v. Teton Therapy, PC

engage in a range of Scientology religious practices and training as a mandatory condition of

amended^ 42 U.S.C. § 200pe, et. seq.

3. Teton Therapy, P.C., is a corporation registered and incorporated in the State of

4. Defendant provides physical and occupational therapy services.

5. Jeff McMenamy is the Owner and Chief Executive Officer of Defendant.

6. Defendant conducts business in the towns of Riverton, Lander, Cheyenne, and

Sheridan, in the State of Wyoming.

to on or about May 24,2013.

8. Defendant forced Ms. Rohrbacher to resign and/or constructively discharged Ms.

Rohrbacher from employment on or about May 24,2013.

Rohrbacher v. Teton Therapy, PC

II. JURISDICTION AND VENUE

9. Jurisdiction is asserted pursuant to Title VII,42 U.S.C. §§ 2000e,2000e-5, and

2000e-5(f)(l)(3), as amended, the Civil Rights Act of 1991,42 U.S.C. § 1981a(a)(1),(b)(1)-

Vn.42 U.S.C. § 2000e(b),(g), and (h).

III. ADMINISTRATIVE PROCEDURES

all required administrative prerequisites, procedures, and remedies.

Employment Practice Act of 1965, as amended.

Rohrbacher v. Teton Therapy, PC

date ofthe EEOC Notice of Right to Sue letter.

IV. GENERAL ALLEGATIONS

19. Ms. Rohrbacher, a female, is forty-six years of age.

20. On or about November 30,2011, Ms. Rohrbacher was hired by Defendant.

facility in Lander, Wyoming.

22. The Church of Scientology is a religion developed by L. Ron Hubbard.

23. At all times in issue, Defendant's management acted through conduct by

McMenamy,and/or conduct taken at the direction of McMenamy.

herein. Plaintiffreasonably believes McMenamy is a practicing Scientologist.

25. Defendant required Ms. Rohrbacher, in the course of her employment, to

26. Defendant, throughout Ms. Rohrbacher's employment, subjected her to

training, and principles of Scientology.

Rohrbacher v. Teton Therapy, PC

27. Defendant's mandatory, Scientology-based, terms of employment, included but

weeklong, management training Scientology-based seminar.

and be subjected to mandatory terms and conditions of employment based on Scientology

religious practices, teachings, beliefs, and training, to be unwelcome, offensive, intimidating,

environment for Non-Scientologists.

30. Defendant, as a mandatory term and condition of employment, required Ms.

Rohrbacher to take and complete the Code Course.

completion ofthe Code Course.

Rohrbacher v. Teton Therapy, PC

33. Ms. Rohrbacher voiced her objections/complamts to the Defendant required

employment based on religious practices, teachings, beliefs, training, and principles of

34. Ms. Rohrbacher's Objections/complaints to Defendant concerning Scientology

principles; and(d)the training was based on Scientology.

teaching, practices, and beliefs of Scientology.