The purpose of this survey is to note important caselaw developments in the state and lower federal courts concerning religious liberty. Purposely omitted are the widely reported United States Supreme Court opinions, as well as cases where the high court has granted review during its 1986-87 term. The focus here is to collect significant cases that may otherwise escape broad attention. Only the facts and rationale of each court's decision is recorded. No editorial comment on the merits of these cases is intended.

Minnesota v. Porter Farms, Inc., 382 N.W.2d 543 (Minn. Ct. App. Feb. 25, 1986).

A Minnesota appeals court has upheld an administrative law judge's ruling that an employee was unlawfully discharged because of his marital status. Randy Fitzloff brought suit under the Minnesota Human Rights Act, Minn. Stat. § 363.01 et seq., claiming that he was discharged from his employment as a farm laborer because he was living with a woman to whom he was not married. Suit was brought against Porter Farms and James Sorenson, who was found to be acting as its agent. Fitzloff, who was employed to help Sorenson with the operation of a farm, lived in a trailer near Sorenson's home. After discovering that Fitzloff was not married to the woman, Sorenson informed him that he was “living in sin” and would have to make a major decision within seven days and carry it out within two months. When again confronted, Fitzloff informed Sorenson that he would probably be getting married but not within two months. Sorenson then purportedly told FitzlofF “you're through.” Fitzloff interpreted the statement as meaning that he was fired and claimed that Sorenson's act constituted discrimination.