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Two cases in 2012 involved employment discrimination claims. In one, a Catholic diocese had refused to renew the contract of a teacher who had sought in vitro fertilization. In another, earlier case, a Lutheran elementary school had terminated the contract of a teacher for 'damaging her working relationship' with the school by 'threatening to take legal action' when she was not permitted to return to work after disability leave related to narcolepsy. In both cases, the employers have argued that the employee's discrimination claims should be dismissed solely because of the religious character of the employer organization. The specific legal defenses in each suit differ somewhat, but ultimately they both rely on the First Amendment to exempt religious employers from civic responsibilities imposed by law on other private employers. [ABSTRACT FROM AUTHOR]