Garrick v. Moody Bible Institute

Becket Role:
Case Start Date:
January 25, 2018
Deciding Court:
U.S. Court of Appeals for the Seventh Circuit
Original Court:
U.S. District Court for the Northern District of Illinois, Eastern Division
Practice Area(s):

Case Snapshot

Since 1886, The Moody Bible Institute of Chicago has been on a mission to educate, train and equip men and women to proclaim the Gospel and promote the Christian faith. Drawn by this mission, students from the U.S. and countries around the world come to Moody to study and prepare for a life where serving Christ is their lifelong calling. Moody’s graduates serve worldwide, answering God’s call and bringing hope, healing, and the Gospel message as leaders in their faith communities. Moody is in federal court defending its ability to train students for Christian leadership in accordance with its beliefs.


On November 5, 2021, a district court wrongly decided that it could weigh into a religious dispute over faith and doctrine. On July 31, 2023, Becket stepped in to protect Moody’s ability to train students for ministry in accordance with its beliefs at the U.S. Court of Appeals for the Seventh Circuit. A divided panel ruled 2-1 against Moody Bible in March 2024.

Case Summary

A historic beacon of faith and hope 

Moody was founded in 1886 by prominent evangelist Dwight L. Moody, at the behest of Emma Dryer – a teacher who was instrumental in helping launch the school. Originally named the Chicago Evangelization Society, the purpose of the school was to train men and women from all walks of life to bring the Christian faith to all people. Today, Moody offers undergraduate, seminary, and missionary aviation training to equip students to proclaim the Gospel of Jesus Christ, to be Biblically grounded, and to engage the world through Gospel-centered teaching and living. Moody offers various degrees to develop the next generation of Christian leaders, including Biblical Studies, Biblical Languages, Biblical Preaching, Pastoral Studies, Theology, Worship Music, Children and Family Ministry, Ministry Leadership, and Communications. Moody offers full-time residential undergraduate students at Moody’s Chicago campus a full tuition grant to help minimize the cost of an undergraduate education, allowing graduates to serve wherever they are called.  

Moody graduates have served the most vulnerable members of society in the U.S. and around the world—all while sharing their faith. For example, Moody missionary aviators fly patients to hospitals in the Democratic Republic of the Congo and medical supplies to remote parts of Papua, Indonesia. A Moody Theological Seminary graduate operates a women’s shelter in Chicago to care for and minister to victims of sexual exploitation. Moody graduates feed the poor in Cambodia and care for refugees from Central and South America. Graduates have also recently traveled to war-torn Ukraine to bring hope and comfort to families driven from their homes and their country. And a statue honoring Moody alumnae Dr. Mary McLeod Bethune, an educator and civil rights activist, was recently erected in the U.S. Capitol’s Statutory Hall. 

In addition to its faith-centered in-person and online education, Moody educates and equips through its media ministries, Moody Radio and Moody Publishers. Moody relies on all aspects of its ministry to share the Gospel message around the world. Moody’s Communications Department and other faculty are foundational in equipping students with the knowledge and expertise to communicate faith and hope to the world.  

A threat to Moody’s 137-year-old ministry 

Every member of the Moody faculty plays a role in the formation of Moody’s students in foundational Biblical truths. Moody ensures that its ministry remains steadfast by asking all faculty to adhere to its religious beliefs. One of these beliefs is that men and women have unique, complementary roles in the local church. Moody believes that all people have equal dignity and value as lovingly created by God, and that Christian women and men can serve as leaders in faith and ministry. Consistent with its interpretation of Scripture, Moody also believes that the specific biblical church office of pastor (or “elder”) is reserved for men who meet the Bible’s stringent spiritual qualifications.

Despite knowing about and agreeing to adhere to these religious beliefs, a Moody faculty member began advocating against them. After her own admission that she did not share Moody’s beliefs and her inability to sincerely sign Moody’s annual doctrinal statement affirmation, the professor’s teaching contract was not renewed. In response, she is asking the government and the courts to take her side in a religious dispute and punish Moody for acting in accordance with its religious beliefs.  

Protecting a religious college’s religious mission 

Faith-based ministries like Moody are free to decide matters of faith and doctrine—including the qualifications for those who hold senior church offices, without judges or juries getting to second-guess those decisions. The law protects the ability of churches and religious organizations to live, teach, and govern in accordance with the teachings of their faith. This is especially important within the context of a religious school like Moody, which is charged with forming the next generations of pastors, leaders, and ministers. 

Further, several religions—including Catholics, Eastern Orthodox Christians, Protestants, Orthodox Jews, and Muslims—make specific distinctions between men and women in their doctrines of religious leadership and worship. The law protects against government intrusion and entanglement in such sensitive religious beliefs at the heart of so many houses of worship. 

On March 18, 2024, a divided panel of the Seventh Circuit ruled 2-1 against Moody.

Importance to Religious Liberty:  

Religious communities — The ability of individuals to gather freely together to worship and teach their religion is a cornerstone of religious liberty. U.S. law has always protected the rights of religious ministries, schools, and churches to be able to make their own rules and live out their own values free from government interference.