CASE NAME

Storms et al v. Carcieri et al

Overview

Plaintiff (Michael Storms) challenges Defendant’s (Greater Somerset County YMCA; YMCA of the USA; David M. Carcieri) policy that board members of the organization must complete an implicit bias training.

Details

Defendant asked Plaintiff to serve on its board. As a policy, Defendant required that all board members complete implicit bias training. Plaintiff did not complete the training and therefore was denied the opportunity to serve on the board. Plaintiff alleges that because this training conflicts with his religious beliefs, the policy is discriminatory and violates his constitutional rights to free speech and free exercise of religion.

On April 3, 2025, Defendant argued that the case should be for failure to state a claim. Specifically, Defendant asserts that because it is not a government actor, the constitutional claims must be dismissed, since constitutional rights like free speech and religious freedom generally only apply to actions taken by the government and not private parties. Regarding the other laws Plaintiff cites, Defendant argues that Plaintiff failed to follow the required procedures for bringing the claim or, in the case of Title VI, that the law does not permit claims of religious discrimination.

On November 10, 2025, a motion to dismiss for lack of jurisdiction was filed by Defendant YMCA of the USA (Y-USA). Y-USA argued that they do not have the required regular and systematic contacts with New Jersey to support a finding of jurisdiction over it. Additionally, Y-USA stated that the local Y associations operate independently with their own governance structures. Y-USA pressed that there is no evidence that they control "the day-to-day operations, hiring, or decision-making of Local Associations".

Court

U.S. District Court, District of New Jersey

Status

Filed February 12, 2025 | Ongoing