Case Explained: ST. DOMINIC ACADEMY, d/b/a Roman Catholic Bishop of Portland, a corporation sole; ROMAN CATHOLIC BISHOP OF PORTLAND, a corporation sole; KEITH RADONIS, on their own behalf and as next friend of children K.Q.R., L.R.R., and L.T.R.; VALORI RADONIS on their own behalf and as next friend of children K.Q.R. L.R.R., and L.T.R v. A. PENDER MAKIN, in the personal capacity and official capacity as Commissioner of the Maine Department of Education; JEFFERSON ASHBY, in the personal capacity; MEGAN SANDERS,* in the official capacity as Commissioner of the Maine Human Rights Commission; EDWARD DAVID, in the personal capacity and official capacity as Commissioner of the Maine Human Rights Commission; JULIE ANN O’BRIEN, in the personal capacity and official capacity as Commissioner of the Maine Human Rights Commission; MARK WALKER in the personal capacity and official capacity as Commissioner of the Maine Human Rights Commission; THOMAS L. DOUGLAS, in the personal capacity and official capacity as Commissioner of the Maine Human Rights Commission * Plaintiffs originally named Jefferson Ashby as a defendant in both his personal capacity and his official capacity as a Commissioner of the Maine Human Rights Commission. Sometime around February 2024, Megan Sanders replaced Jefferson Ashby on the Maine Human Rights Commission. Commissioners, Me. Hum. Rts. Comm’n https://www.maine.gov/mhrc/about/commissioners [https://perma.cc/AQ4H-47JF] (last visited Apr. 28, 2026). As to the claims against Ashby

Court: United States Court of Appeals for the First Circuit

Filed: 2026-07-02

The First Circuit affirmed in part and reversed in part the district court’s order denying St. Dominic Academy’s motion for a preliminary injunction against Maine’s Human Rights Act (MHRA) provisions. The court held that the school lacked standing to challenge the Employment Rule because statutory carveouts explicitly permit religious schools to hire only co-religionists and require employees to conform to religious tenets, eliminating any credible threat of prosecution. Regarding the Religious Nondiscrimination Rule and the Sexual Orientation and Gender Identity Nondiscrimination Rule, the court concluded the school failed to show a likelihood of success on the merits; it determined these rules are neutral and generally applicable under *Employment Division v. Smith*, subject only to rational basis review, which they satisfy given the state’s legitimate interest in preventing discrimination in publicly funded education. However, the court reversed the denial of injunctive relief concerning the Religious Expression Rule, finding that St. Dominic had demonstrated a likelihood of success on its First Amendment claim. The court ruled that the rule is facially nonneutral because it singles out “religious expression” for special regulation compared to other forms of identity-based expression, thereby failing strict scrutiny as it does not advance an interest of the highest order necessary to justify infringing free exercise rights. Consequently, the case was remanded with instructions to enter a preliminary injunction specifically against the Religious Expression Rule as applied to St. Dominic. The court also dismissed the parental-rights claims as moot due to the Radonises’ change in circumstances and substituted Megan Sanders for Jefferson Ashby regarding official-capacity claims under Federal Rule of Appellate Procedure 43(c)(2).

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