Full opinion text
ENTRY ON ALL PENDING MOTIONS BARKER, District Judge. I. Introduction and Outline. This is an employment discrimination case involving alleged religious harassment and disparate treatment in violation of Title VII, 42 U.S.C. §§ 2000e et seq, as amended, 42 U.S.C. § 1981a. The case consists of two categories of claims: “pattern or practice” claims and individual disparate treatment claims. Both categories include allegations of hostile work environment and allegations of job discrimination. More specifically, the complaint alleges that the defendants (collectively known here in the singular as “Preferred”) engaged in a pattern or practice of unlawful conduct, in that it systematically created or condoned a hostile and abusive work environment based on religion, and systematically engaged in discriminatory employment actions on the basis of religion. It also alleges disparate treatment claims on behalf of seven individual complainants in that Preferred allegedly created or condoned a hostile and abusive work environment based on religion affecting six of the complainants, and unlawfully based specific employment decisions affecting all seven complainants on religious criteria. The case is before us on defendant’s motion for summary judgment as to all claims. We also address here three collateral but significant matters. Two of the collateral issues were raised in Preferred’s “Establishment Objections” (which we construe as a motion to strike certain of the EEOC’s statements of fact and the evidence upon which they rest) and in the EEOC’s Motion for Partial Summary Judgment on Preferred’s affirmative defenses. The third preliminary issue was raised by Preferred on summary judgment. It alleges that some of the EEOC’s claims do not rest on a timely charge of discrimination so that the EEOC’s pattern or practice claim is time barred, as is the failure-to-hire claim on behalf of Teresa Raloff. We address these pending motions and related matters here because they are inextricably intertwined with the merits on summary judgment. Because this ease is complicated, we acknowledge that this Entry is long. Accordingly, we provide the following outline in order to facilitate access to its various parts and analyses. II. Statement of Facts A. Facts Generally Relevant to All Claims.' B. Facts Pertinent to Individual Claims. 1. Theresa Raloff. 2. Sondra Sievers a. Facts Pertaining to Religion. b. Events Leading to Ms. Sievers’ Demotion and Discharge. 3. Ellen Blice. a. Background. b. Events Leading to Ms. Blice’s Termination. 4. Suzanne Elder. a. Background. b. Ms. Elder Resigns from Employment. 5. Sherry Stute. 6. Diana DeWester. 1.Mary Mulder. III. ■ Analysis A. Summary Judgment Standard B. Preliminary Matters 1. Preferred’s “Establishment Objections.”' 2. Charge Filing Statute of Limitations and Teresa Raloffs Claim 3. EEOC’s Motion for Partial Summary Judgment C. Hostile Environment and Constructive Discharge. 1. The Law of Hostile Environment. 2. Pattern or Practice. 3. Individual Harassment Claims. a. Sondra Sievers b. Ellen Blice c. Suzanne Elder d. Sherry Stute e. Diana DeWester f. Mary Mulder 4. A Note on Coercion 5. Vicarious Liability versus Negligence 6. Constructive Discharge D.Individual Disparate Treatment Claims. 1. Legal Analysis 2. Sondra Sievers: Demotion, Discharge, Retaliation. a. Ms. Sievers’Demotion. b. Ms. Sievers’Discharge c. Retaliatory Discharge 3. Ellen Blice a. Discriminatory Discipline b. Discriminatory Discharge i. The Decision Maker ii. Ms. Blice’s Discharge 4. Sherry Stute: Failure to Promote. IV. Conclusion. For the reasons explained here, We DENY Preferred’s motion for summary judgment except with respect to the EEOC’s claim that Ellen Blice was the victim of discriminatory discipline. We construe Preferred’s “Establishment Objections” as a motion to strike and DENY that motion. We GRANT the EEOC’s motion for partial summary judgment in all particulars, except for its request that we find as a matter of law that PMC is a proper defendant and except for its request that we find admissible all evidence of Preferred’s conduct before June 18, 1995 and after July 26, 1996. To the extent that Preferred’s arguments concerning statute of limitations may be viewed as a motion separate from its motion for summary judgment, we DENY that motion and conclude that none of the EEOC’s claims is barred by any statute of limitations. II. Statement of Facts A. Facts Generally Relevant to All Claims. It is a commonplace of summary judgment jurisprudence that we recite the facts in a light reasonably most favorable to the plaintiff as the party opposing summary judgment and that we resolve all disputes of fact in the plaintiffs favor. These principles are of more than ordinary importance here, because many of the facts, and even the facts’ nuances, are hotly contested. Where, as here, the parties advance different theories of the case, they tend to question whether certain facts are even relevant, much less material. We remind the parties — and particularly the defendant moving for summary judgment — that, since we do not weigh the evidence, we do not seek a “balanced” recitation of the facts. We recite the facts “uniformly favorable” to the non-moving party. Venters v. City of Delphi, 123 F.3d 956, 962 (7th Cir.1997). Similarly, notwithstanding Preferred’s objections to the EEOC’s “selective editing” and other literary devices, the EEOC has no duty on summary judgment to be “fair” or “balanced” or “complete” in its presentation of the facts. Fairness is for trials. Summary judgment tests only whether the plaintiff has presented legally sufficient evidence to go to trial. Accordingly, the EEOC’s only obligation on defendant’s motion for summary judgment is to present admissible evidence tending to raise genuine issues of material fact. 1. The Company and its Management Personnel. The Preferred companies consist of four operating companies, a real estate company, and a management company. Pl. Add. Facts, ¶ 661. All of the Preferred entities are owned equally by Jackie Steu-erwald and Greg Steuerwald (husband and wife). Pl. Add. Facts, ¶ 663. All of the Preferred companies use the same personnel manual, financial policies, and employee benefits. Pl. Add. Facts, ¶ 664. With the exception of Preferred Properties, all of the Preferred entities have the same officers and board of directors. Pl. Add. Facts, ¶ 665. Preferred Management Corporation (hereafter “PMC”) provides training for all of the operating companies; it also manages the operating companies’ payrolls, finances, information systems, and human resources. Pl. Add. Facts, ¶¶ 667, 667. The defendants here are the Preferred entities that are engaged in operating home health care services. We refer to them collectively throughout as “Preferred.” Michael Pyatt was employed by PMC as Director of Human Resources from October 1994 through 1998. He was a member of the executive management team. He had authority to hire for any position within the company and oversight of all decisions to terminate. He was responsible for all training with respect to personnel. He also participated in creating and reviewing company policies. Pl. Add. Facts ¶¶ 678-683. Denise Sehrock is Preferred’s Chief Financial Officer. As CFO, her primary responsibility is the company’s fiscal condition and its overall management. She also helps make company policy. Pl. Add. Facts, ¶¶ 684-687. Diane Christian started as a director of training and development in 1991; she later became the company’s Northern Area Administrator. As the Northern Area Administrator, her job duties included visiting the northern branches and meeting with the branch managers to discuss issues in the office such as client load, patient problems, personnel issues and issues in the health care market. In 1995 or 1996, she became Preferred’s Chief Nursing Officer, which made her a member of the executive management team. PI. Add. Facts ¶¶ 688-690. Ann Parker was Preferred’s Southern Area Administrator from some time in 1990 through November 1995. As Southern Area Administrator, she supervised branch managers in the Vincennes, Jasper and Washington offices. PL Add. Facts ¶¶ 692, 693. Teresa Jennings (later Hedges) was promoted to Southern Area Administrator in December 1995. As the Southern Area Administrator, she had authority to hire and fire employees. PI. Add. Facts ¶¶ 694, 697. Gregg Johnston was the Director of Program Development at Preferred and was responsible for marketing. PI. Add. Facts ¶ 698. Nellie Foster was initially hired as a consultant for Preferred; in January 1996, became a member of the corporate team as a training and development manager. Ms. Foster’s previous work experience included working as a minister of Christian education at the Southwest Church of God. Sue Klein became the interim branch manager for the Vincennes branch in mid-November 1995. After being interviewed by a panel, Darlene Wright sent a summary of the panel’s evaluations to Jackie Steuerwald, who decided to promote Ms. Klein to the branch manager position. Ms. Klein had had no managerial experience prior to being named interim branch manager at Vincennes. As an interim branch manager and as a branch manager, Sue Klein’s responsibilities included overseeing the functions of the office and the staff, managing the financial aspects of the branch, hiring employees, and disciplining employees. PI. Add. Facts ¶ 712, 734-737. Wanda Wallace became acting branch manager for the Evansville branch in February 1996. Ms. Wallace trained and supervised Sherry Stute. PI. Add. Facts ¶¶ 738-740. Since 1990, Darlene Wright has been the personnel director for the southern district of Preferred. Ms. Wright’s responsibilities include pre-screening of applications, preliminary interviewing of applicants, making recommendations to supervisors about applicants, making recommendations about corrective actions and discipline, and making recommendations for termination. PI. Add. Facts ¶¶ 741, 742. Donna Drew started as a field nurse in 1993. In 1996 or 1997, she was promoted to be RN Supervisor in the Vincennes office. PI. Add. Facts ¶¶ 743-744. 2. Religion and the Work Place. Preferred’s guiding hand is Jackie Steu-erwald, the company’s co-owner and chief executive officer. Def. Facts, ¶ 2. Ms. Steuerwald identifies herself as a practicing Christian who adheres to a literal interpretation of the Bible, which she reads daily. She professes a concept of salvation by the grace of God and that she is “born again.” Ms. Steuerwald believes that God directed her to establish PHHC in Vin-cennes and that Preferred is God’s home health care agency. She openly shares these beliefs with her employees. Ms. Steuerwald has prepared a narrative entitled “The Transfiguration of Preferred,” a brief history of the company’s formation, which discusses her belief that God was involved in Preferred’s establishment and is involved in Preferred’s direction. Def. Facts, ¶¶ 9-16. PI. Add. Facts, ¶ 815. Ms. Steuerwald believes in “The Great Commission,” a religious directive to go into the world to share her faith. “The world” includes the work place. Def. Facts, ¶¶ 19-20. Asked whether she believes that religion is appropriate in the workplace, Ms. Steuerwald responded: “I don’t believe it can be ... If you’re a person of faith, it can’t be separated.” Steuerwald Dep., I, 69. She added by way of explanation: “Well, in Him I live and breathe and have my being, and I don’t leave my faith at the door when I go to work. It’s who I am. It permeates my thinking, my decisions.” Steuerwald Dep., I, 69. Ms. Steuerwald anoints new branch offices with olive oil and asks God’s blessing on each new office. Def. Facts, ¶ 18. When a new office is anointed, the ceremony is conducted during working hours. PI. Add. Facts, ¶ 810. Ms. Steuerwald also has anointed two existing facilities, in Terre Haute and Evansville, because of strife and discord in those offices. Ms. Steuerwald testified that she discerned demons in those offices and that by anointing them she believed she was able to rid the offices of the demons. PI. Add. Facts, ¶ 803, 806, 807. Ms. Steuerwald also has anointed individual employees of Preferred for healing purposes. She believes that anointing has healing power. PI. Add. Facts, ¶ 811, 812. Ms. Steuerwald defines Preferred’s mission as presenting God and his Son, Jesus Christ, to all of Preferred’s employees. Def. Facts, ¶ 23. Preferred’s mission statement includes that its primary mission is “to be a Christian dedicated provider of quality health care.” Def. Facts, ¶ 30. Preferred employs an “evangelism and discipleship” subcommittee, whose members have prayed for the salvation of employees. Def. Facts, ¶¶ 27, 28. Beginning in June 1995, Preferred has required its employees, as a condition of employment, to sign a statement that includes the words: “I have examined myself and I agree that I have respected and actively supported Preferred’s Mission and Values during this past year of employment and I agree to respect and actively support Preferred’s Mission and Values for the coming year.” Def. Facts, ¶37; PI. Add. Facts, ¶ 824. Preferred’s managers and supervisors are instructed to use the company’s values in disciplining employees because values are considered a standard of performance. Def. Facts, ¶ 41. Preferred employees are evaluated according to the Mission and Values Statement. PI. Add. Facts, ¶ 841. They are also disciplined on the basis of the Mission and Values Statement. PI. Add. Facts, ¶ 843. Religious references are made on employee evaluations. PL Add. Facts, ¶ 842. Employees were terminated for violating the values in the Mission and Values Statement. PL Add. Facts, ¶ 844. Preferred’s corporate organizational chart is known as “the wheel.” At its center is the name “Jesus,” who represents the rock upon which Preferred professes to be built. From this center, all of Preferred’s departments radiate as spokes. Def. Facts, ¶¶ 43^4. During comprehensive orientation or a management meeting, Ms. Steuerwald had a wheel on the board with Jesus in the middle and employees’ names on the spokes. She told those in attendance that, with Jesus as the foundation of Preferred and the employees there providing the care, Preferred would grow and benefit. During the comprehensive orientation that Sherry Stute attended, Ms. Steuerwald said that it was a vision of hers that the conference room at Preferred would some day be a church and that people could come there and pray. Pl. Add. Facts ¶¶ 1246,1247. Preferred gives copies of the company’s mission statement, statement of values, definitions, “the wheel,” and the “Transfiguration” to all applicants as they apply for employment. Def. Facts, ¶ 45. Applicants are informed that Preferred is a Christian organization and that prayers are recited at the company; they are asked how they feel about working for a Christian organization. Pl. Add. Facts, ¶ 827. Former branch manager Sondra Sievers testified that Ms. Steuerwald told her and others that a candidate for employment who said that there was no room in the work place for religion did not belong at Preferred. Pl. Add. Facts, ¶ 828; Sievers Decl., ¶ 11. A Mormon who also was a candidate for employment, was not hired. The chaplain who interviewed the candidate told others who had been present at the interview that Mormonism is a “cult.” Pl. Add. Facts, ¶ 828; Fennell Dep., 28-30. Preferred offers religious gatherings, which it refers to as “devotions,” to its employees on a weekly basis. The devotions are facilitated by two staff chaplains. Def. Facts, ¶¶ 46-47. Preferred states that there was no corporate-wide policy of mandatory attendance at devotions. Def. Facts ¶ 48. By contrast, Ann Parker testified that, as a manager she was required to be a “role model,” which meant, among other things, that she was “expected” to attend and was required to embody and exemplify corporate policy. Ms. Parker also testified that she discussed the manager’s responsibilities with Sherry Stute when Preferred was going to open an Evansville facility and one responsibility was to attend devotions. Accordingly, she perceived devotions to be mandatory. Parker Dep., pp. 38-40. Human Resources Director Michael Pyatt professes to be a follower of Jesus Christ. Mr. Pyatt testified that he is saved or born again and that all of the churches he has attended are fundamentalist. Pl. Add. Facts ¶¶ 756-758. On two occasions, Mr. Pyatt conducted devotions at a branch office. Pl. Add. Facts, ¶ 831. Prayer and “script devotion” on various themes are conducted at the weekly devotions. Pl. Add. Facts ¶ 838. Ms. Steuer-wald sometimes commented about employees’ attendance at devotions. Pl. Add. Facts ¶¶ 833-835, 914, 1488. Employees are not told that they may leave meetings before prayer is conducted. Pl. Add. Facts, ¶ 840. The handwritten document, “Expectations of Branch Manager,” included the following items: (1) actively demonstrate company values, behavior standards of branch manager (attached) and (2) devotions are held weekly at a scheduled time. Pl. Add. Facts ¶ 1474; Sue Klein became the interim branch manager for the Vincennes branch in mid-November 1995. She was interviewed for the regular branch manager position on December 20, 1995 by a panel consisting of Darlene Wright, Terry Jennings and Chaplain Chuck Harrington. The interview panel asked Ms. Klein: “How has your association with Preferred affected you personally since you were hired?” Ms. Klein responded that her association with Preferred had a tremendous impact professionally and spiritually, that she loves to share her beliefs about Jesus and is able to do that at Preferred. The interview panel asked Ms. Klein: “What significant growth have you experienced in the past year and what brought it about?” Ms. Klein responded that she experienced growth of a spiritual nature and knew that she rested in God’s hands and that God is in charge. The interview panel asked Ms. Klein to name three assets that she would bring to the branch manager position. She responded: “Caring, Dependence on the Lord, and Willingness and desire to do the job.” The interview panel asked her: ‘What temperment [sic] traits and/or characteristics do you have that would enable you to be an effective manager?” She responded that she tries to be gentle in approach, listens to all sides of different situations and “takes all situations to the Lord in prayer.” Pl. Add. Facts ¶¶ 712-722. The interview panel asked Ms. Klein “What role do you feel evangelism plays in the position of branch manager?” She responded: “Spreading the Gospel is dear to my heart. The opportunities are endless with Preferred. Shared an opportunity to share the power of God yesterday with Lori Merchant, Physical Therapist.” The interview panel asked Sue Klein, “What motivates you as a person?” She responded: “Faith in the Lord Jesus Christ.” Pl. Add. Facts ¶¶ 723-725. In evaluating their interview with Ms. Klein, panel members indicated whether they would hire her and why, including such comments as: “I appreciate her strong faith in Jesus and because faith is a priority with her. She also has a spirit of cooperation; ... she has Godly values; ... Sue’s faith is devoted and inspiring.” Panel members wrote the following types of comments to the question “Could you identify their values in the interview and what were they?” in Sue Klein’s interview: “Honesty, Integrity and a dependence on the Lord for guidance; God is her source of wisdom and strength; Faith, honesty, integrity and caring; Integrity, Trust in God, Fairness, honesty, non-indispensabili.ty.” Pl. Add. Facts ¶ 731, 732. Darlene Wright compiled the responses of the panel members and wrote the following summary on Sue Klein’s interview: The committee identified Sue as a person with integrity who exemplifies honesty and fairness. She derives her wisdom and strength from the Grace of God. * * * The concerns of the committee were her lack of knowledge regarding regulations and the financial aspects of the branch. It was also noted that she fails to see “The Big Picture” in regard to Branch Operations. We feel with Sue’s willingness to learn, and intelligence she will succeed as an effective Branch Manager. Pl. Add. Facts ¶ 733. After Sue Klein became acting branch manager for the Vincennes branch, she told Ellen Blice that Ms. Blice had 'to attend devotions because she needed to learn to be more humble. Ms. Blice declined to attend because such devotions were contrary to her religious beliefs. Pl. Add. Facts ¶¶ 1082, 1083. At the February 14, 1996, devotions, Ms. Steuerwald handed Ellen Blice a song sheet for the song beginning “He is a mighty God” and said “You need to sing this.” Pl. Add. Facts ¶ 1114. Christine Fennell was reprimanded at one point during her employment at Preferred for missing too many devotions. Pl. Add. Facts ¶ 1446. As a consultant and as a trainer and developer, Nellie Foster was responsible for teaching the “Leader in the Making” program to corporate and branch managers. Ms. Steuerwald described The Leader in the Making program to employees as a way to “understand Jesus modeled leadership.” Ms. Foster spoke about scriptures in her management training and referenced scriptures, the Bible, and religion in the handouts she distributed in training sessions. Corporate and branch managers were required to attend sessions for the Leader in the Making management program. In conjunction with the area administrators, Ms. Foster had authority to decide who met the qualifications for the Leader in the Making program. Ms. Foster also did training sessions in the branches for the branch staff. Pl. Add. Facts ¶¶ 699-708. Preferred’s CEO, Jackie Steuerwald, sent a letter to Preferred staff that reads, in part: “I would ask every employee at Corporate and each Branch to be involved in this training [Leader in the Making programs]. You will be notified by a memo as to which track you will be a part of.” Pl. Add. Facts ¶¶ 709, 710. Preferred also encourages prayer in the workplace outside of devotions. For example, prayers are recited before employee meetings. Pl. Add. Facts ¶ 839. Sondra Sievers testified that Vincennes branch had prayer at weekly devotions and then employees began praying for help with anything and everything. Pl. Add. Facts ¶¶ 910, 912. Ellen Blice testified that a prayer was recited before each meeting that Ms. Steuerwald conducted. Pl. Add. Facts ¶ 1070. At times, branch manager Sue Klein would grab Sherry Stute’s arm, as well as the arms of other employees, and ask: “Have you prayed today?” Pl. Add. Facts ¶¶ 1203, 1204. “Leader in the Making” presentations always started out with prayer. Pl. Add. Facts ¶ 1206. Prayer also was conducted each day at comprehensive orientation and branch manager meetings. Pl. Add. Facts ¶¶ 1243, 1251. As Director of Human Relations, Michael Pyatt did not conduct any training on religious harassment or religious discrimination for Preferred employees, nor did Mr. Pyatt have training on religious harassment. Pl. Add. Facts, ¶ 845, 847. Preferred’s manual, used by directors to train branch managers, did not contain any reference to religious harassment. Also see Pl. Add. Facts, ¶ 846. Preferred branch managers, supervisors, and office managers- — including Terry Jennings, Ann Parker, Sue Klein, Wanda Wallace, Nellie Foster, Kathy Robinson, Rebecca Seim, Karen Lemons, and Carol Smith — received no training with respect to religious discrimination or to the handling of potential complaints concerning religious discrimination or harassment. Pl. Add. Facts, ¶¶ 846-856. B. Facts Pertinent to Individual Claims. The EEOC has brought hostile environment harassment claims on behalf of six employees: Sondra Sievers, Ellen Blice, Suzanne Elder, Sherry Stute, Diana DeW-ester, and Mary Mulder; and individual disparate treatment claims on behalf of seven employees: Suzanne Elder, Sherry Stute, Diana DeWester, Mary Mulder (all four alleging constructive discharge); Sondra Sievers (alleging demotion and discharge based on religion and/or retaliation); Ellen Blice (alleging discriminatory discipline and discharge); Sherry Stute (alleging failure to promote); and Theresa Raloff (alleging discriminatory failure to hire). We turn now to the factual background of these claims. In doing so, we note that many of the facts pertaining to the individual claims also have a bearing on the pattern or practice and environmental claims. 1. Theresa Raloff. Theresa Raloff applied for the Director of Nursing (“DON”) position in Preferred’s Lafayette Branch. She interviewed in February 1995. As part of the interview,. Ms. Raloff met with Ms. Steuerwald. Preferred acknowledges that Ms. Steuerwald terminated the interview because of Ms. Raloffs religious beliefs. Def. Facts ¶¶ 655-658. Specifically, Ms. Steuerwald asked Ms. Raloff: ‘What kind of religion are you anyway?” Ms. Raloff responded: “Unitarian.” Ms. Steuerwald replied: “You damned humanists are ruining the world” and told Ms. Raloff that she was going to burn in hell forever. She told Ms. Raloff the interview was terminated because Ms. Raloff was inappropriate for the company. She also told Ms. Raloff that she would pray for Ms. Raloffs soul. Pl. Add. Facts ¶¶ 1621-1623. 2. Sondra Sievers a. Facts Pertaining to Religion. Sondra Sievers served as a branch manager and nursing supervisor in Preferred’s Lawreneeville facility for three years, from May 1990 until her promotion to branch manager at the Vincennes facility in 1993. Def. Facts ¶ 58. She was demoted from branch manager on November 14, 1995 and replaced by Sue Klein. Pl. Add. Facts ¶ 989; Def. Facts ¶ 129. She was discharged from employment on March 8, 1996. Def. Facts ¶ 186. Ms. Sievers has been a practicing Catholic all of her life. Def. Facts, ¶ 50. She considers herself to be a Christian in that she is baptized and believes in Jesus Christ. Def. Facts, ¶ 51. She does not, however, believe in the idea of being saved or born again. Pl. Add. Facts ¶¶ 898. Ms. Steuerwald knew that Ms. Sievers was a Catholic. Def. Facts ¶ 60. During a luncheon with Ms. Sievers and employees Chuck Harrington and Ann Parker, Jackie Steuerwald asked Ms. Siev-ers, while giggling, whether it is “really true that you keep the Holy Spirit in a box at the front of your church?” Pl. Add. Facts ¶ 901; Def. Facts ¶ 67. Ms. Sievers was embarrassed by the question and made uncomfortable by it. Pl. Add. Facts ¶ 902. Ms. Sievers signed Preferred’s Mission and Values Statement, although she was uncomfortable doing so. She believed she had to sign the document as a condition of employment. Pl. Add. Facts ¶¶ 906, 907. As a Preferred employee, Ms. Sievers watched religiously-oriented videos at work. She believed she was expected to watch the videos because Ms. Steuerwald talked about religion in every conversation and in every meeting that Ms. Sievers heard or attended. As a Catholic, Ms. Sievers was offended by the content of the videos and also thought it inappropriate for Ms. Steuerwald to imply that Medicare should pay for her to evangelize. Pl. Add. Facts ¶¶ 908, 909; Sievers Dep., 215-220. Ms. Sievers perceived prayer to be a regular aspect of the work place. Pl. Add. Facts, ¶ 910. Ms. Sievers testified that, at the Vincennes branch, prayer was conducted at weekly devotions, and then employees began praying for help with anything and everything. After Sue Klein arrived as interim branch manager, prayers were conducted every morning. Pl. Add. Facts ¶ 912; Sievers Dep., 188-189. Ms. Sievers’ supervisor at the Law-renceville facility, Ann Parker, told Ms. Sievers that Jackie Steuerwald knew which employees attended devotions and that Ms. Steuerwald expected employees to attend. Pl. Add. Facts ¶¶ 914. She also told Ms. Sievers that Ms. Steuerwald wanted staff meetings opened with prayers. Pl. Add. Facts ¶ 915.. While Ms. Sievers was still working at the Lawreneeville branch, she told Ms. Parker that she was uncomfortable with the way religion was “pushed” at Preferred. Pl. Add. Facts ¶ 916. Ms. Parker recommended that Ms. Sievers read the book, “This Present Darkness,” a book about spiritual warfare, which, she said, might help Ms. Sievers understand the beliefs of Jackie Steuerwald, Darlene Wright and other people with whom Ms. Sievers was working. PI. Add. Facts ¶¶ 917, 918. Ms. Sievers received religious memos at work that were distributed in her tray or mailbox. As a branch manager, she also received from Mike Pyatt’s newsletters called “Focus on Managing,” some of which contained Biblical and religious references. PL Add. Facts ¶¶ 919, 920. At various business meetings which Ms. Sievers attended, religion was a topic of discussion. Jackie Steuerwald conducted presentations and meetings which Ms. Sievers attended in which Ms. Steuerwald talked about her religious beliefs. PI. Add. Facts ¶¶ 922, 928. Marketing Director, Gregg Johnston, held a branch-manager meeting which Ms. Sievers attended in which he used the Bible, and he gave the attendees a book that related to the Bible. Human Resources Director Pyatt also conducted meetings at which he injected religious topics. So did Johnny Garrison, one of Preferred’s chaplains who also conducted devotions. PI. Add. Facts ¶¶ 924, 925, 926. As a branch manager, Sondra Siev-ers was expected to attend all branch meetings. PI. Add. Facts ¶ 927. Ms. Sievers was uncomfortable attending some meetings. At one meeting, Ms. Steuerwald discussed her visit to Cuba, during which she distributed Bibles to Cubans. Ms. Sievers was uncomfortable because she did not expect to hear about passing out Bibles in a business meeting. Def. Facts, ¶¶ 88-90; PI. Add. Facts ¶ 928. At the same time, she felt excluded or marginalized by not being invited to participate in certain events related to business. She felt slighted that Jackie Steuer-wald did not invite her to attend a prayer meeting at Ms. Steuerwald’s home. She also felt slighted that she was not invited to attend a religious video showing at the Vincennes office. Ms. Sievers thought these exclusions revealed that Ms. Steuer-wald did not believe that she fit in at Preferred. PI. Add. Facts ¶ 982, 933. b. Events Leading to Ms. Sievers’ Demotion and Discharge. Ms. Sievers’ first performance evaluation was at the end of her first six months. Her supervisor at the time, Annette Dodd, identified concerns about her performance, including comments that she at times appeared “too good to learn from her subordinates,” and that she did not appear focused at work. Def. Facts ¶ 93. Thereafter, at her annual evaluation, Ms. Sievers’ new supervisor, Ann Parker, observed that Ms. Sievers appeared to have undergone a change in her attitude because she was taking a more positive and progressive approach to problems. Def. Facts ¶ 94. Indeed, on her annual evaluation of June 27, 1991, Ms. Sievers received ratings of 7, 8, 9, or 10 in 30 categories. Ratings of “7” or “8” mean “consistently over achieves” and ratings of “9” or “10” mean “outstanding.” PI. Add. Facts ¶¶ 937, 938. On her last review before her promotion to Vincennes, it was noted that Ms. Sievers needed to improve the timeliness of “difficult” personnel evaluations of her subordinates. Def. Facts ¶ 95. In Ms. Sievers performance evaluation for May 1994, Ann Parker noted that there had been some hard feelings in the Vin-cennes office relating to Ms. Sievers management style, that Ms. Sievers needed to work on developing a “softer, less controlling ‘people side,’ ” and that she needed to be “more specific” in her communications. Two employees transferred to Lawrence-ville ostensibly because of Ms. Sievers approach to managing the Vincennes branch. Def. Facts ¶¶ 96, 97. On her May 1995 evaluation, Ms. Siev-ers received a “2.3” out of “3”; “3” was the highest possible rating. Def. Facts ¶ 98. Before writing up the May 1995 evaluation, Ann Parker sent out surveys to people in the office and field staff. Ms. Parker does not remember receiving any negative responses from these surveys regarding Ms. Sievers’ work performance. Ms. Parker, who served as Ms. Sievers’ supervisor until November 1995, thought Ms. Sievers was doing a good job and was working hard at being a good leader and manager. Ms. Parker had been instructed in a management meeting to include “trust in the Lord” as part of the employee evaluation process. Accordingly, her May 1995 evaluation of Ms. Sievers included a section addressing Preferred’s values, and Ms. Parker wrote the words “in the Lord” next to the value of “trust.” PI. Add. Facts ¶¶ 943, 944, 946; Def. Facts ¶ 99. The “trust in. the lord” reference came from Preferred’s “behavior tags.” For the value “Trust in the Lord and not your own understanding,” the related behavior, tags are “assured reliance,” “constant verbal expression of faith,” and “positive response to negative situations.” Preferred managers were expected to comply with the behavior tags. PI. Add. Facts ¶¶ 945-948. On October 24, 1995, Ms. Steuerwald conducted a “Values Presentation” at Preferred’s Vincennes branch. During the meeting, Ms. Steuerwald shared how God had changed her life and asked each of the participants to share how they had come to Jesus Christ. Ms. Sievers was uncomfortable with the question because she never had a “big conversion” and knew that Ms. Steuerwald’s perception of how one becomes a Christian was different from hers. In her response to Ms. Steuerwald’s query, Ms. Sievers stated that she was very fortunate to have been born into and raised by a Catholic family and that God had always been a part of her life. At the meeting, Sherry Stute also talked about joining a Catholic church and becoming Catholic. Ms. Sievers was uncomfortable with this meeting. She felt that it involved sharing personal information and she did not believe Ms. Steuerwald’s past sins were any of her concern; additionally, she felt that Ms. Steuerwald was putting people on the spot to talk about their personal relationships with God. Def. Facts ¶¶ 112— 116; PI. Add. Facts ¶ 972. On November 2, 1995, at a breakfast meeting in Vincennes with Chuck Harrington and the branch managers for the southern branches, Ms. Steuerwald stated that if her managers were not where they should be spiritually, they should resign. Ms. Sievers believed that Ms. Steuerwald was looking directly at her when she made this remark. After making the comment that if her managers were not where they should be spiritually, they should resign, Jackie Steuerwald said: “I have done this with my top management people, and your area director, Ann Parker, has resigned.” The next day, Ms. Sievers spoke with Ms. Steuerwald for two hours by phone about this statement, because Ms. Sievers interpreted the remark as directed at her. She told Ms. Steuerwald that she, too, had a personal experience of God, to which Ms. Steuerwald responded: “Well, you know, you’ve never said this to me before.” Ms. Sievers was offended by Ms. Steuerwald’s response because she thought it was none of her business. Ms. Sievers believed she had to make some profession of faith to Ms. Steuerwald in order to keep her job. Def. Facts ¶¶ 117-119; PI. Add. Facts ¶¶ 975-978. In September and October 1995, Preferred’s management team developed a survey relating to employee satisfaction. Entitled “Your Opinion Counts,” the survey covered a number of areas, including working conditions, training, compensation, and advancement opportunities. It also included the question: “Are the Company’s Values actively promoted and modeled by supervisors and managers?” And the request: “Please make any other comments or suggestions that you believe would help Preferred be more effective and be a better place to work and serve the Lord and our customers,” providing space for comments. Def. Facts ¶ 108, 109; Pl. Add. Facts ¶¶ 962, 963. Human Resources director Mike Pyatt distributed the survey to all of the employees-in the Vincennes branch on October 25, 1995. Def. Facts ¶ 111. As he did so, he was asked by an employee what would happen as a result of the survey. Mr. Pyatt responded that “they were looking at all the managers and if they weren’t where they thought they should be, there would be changes made.” Pl. Add. Facts ¶¶ 965, 966. Fifty-nine surveys were given out. Thirty-four employees responded. Def. Facts ¶ 123. Some of the responses were negative with respect to Ms. Sievers. Def. Facts ¶ 124. The negative responses included: (1) “We have lost a lot of very good, kind, caring office and field staff because of the branch manager and it sure is a shame;” (2) “Sondra does not respect our opinion. If we voice our opinion she will usually disagree and then she will be angry”; (3) “Sondra has us all very unhappy with her lack of responsibility, caring or understanding”; (4) “Sondra does not like others, is either [sic] revengeful with field staff, clients and families”; and (5) “If a person isn’t liked or if a person does a job well, branch manager will do anything to create problems for the person.” Def. Facts ¶ 125. These comments appeared on three of the thirty-four surveys returned to Mr. Pyatt. Pl. Resp. to Def. Facts ¶ 125. After receiving the results of the survey, on November 14, 1995, Ms. Steuerwald and Mr. Pyatt went to Vincennes to inform Ms. Sievers of her demotion. Def. Facts ¶ 127. Ms. Sievers met with Mr. Pyatt who addressed the survey results and told Ms. Sievers that she would be removed from her position, placed in the Leader in the Making program with Nellie Foster, and re-evaluated by December 31, 1995. He also gave Ms. Sievers three documents. The first outlined the “qualifications” of a Leader in the Making as (1) having a teachable spirit, (2) having love for one another, (3) honoring others above self; (4) being approachable; (5) willing to ask others for help and advice; and (6) willing to invest in others. The second, entitled “Confess-Repent-Turn,” outlined what Ms. Sievers needed to accomplish by December 31, including (1) restoring broken relationships with Cherie Deem, referral sources, patients and staff; (2) submitting to authority; (3) regaining trust and respect of the staff and community; and (4) consistently walking in a blameless way to be above reproach. The third document was called “Characteristics of Broken People Prepared for Revival.” Def. Facts ¶¶ 133-136. After the meeting, Mr. Pyatt told Ms. Sievers to take three days off and pray and think about things. Def. Facts ¶ 138 and Pl. Resp. Regarding leadership training, Nellie Foster, Preferred’s training and development manager and also a minister, had developed the “Leader in the Making” program discussed earlier; the program included twenty-four lessons and Ms. Foster was going to customize a training program for Ms. Sievers’ circumstances. Def. Facts ¶¶ 127, 128. The customized training involved meetings between Ms. Sievers and Ms. Foster on December 5 and 6, 1995. The December 5 meeting was religiously-oriented. Pl. Add. Facts ¶¶ 1018, 1019. At the December 6 meeting, Ms. Foster presented the “Lordship Ladder” to Ms. Sievers. Ms. Foster asked Ms. Sievers where she was on that ladder, to which Ms. Sievers responded, “Well, I’m certainly not on the sixth step,” signifying a life filled with peace. Def. Facts ¶¶ 166, 167. Ms. Foster then asked Ms. Sievers: ‘What was the last sin you committed?” and “What was the last thing you asked God forgiveness for?” Ms. Sievers responded, “I am a Catholic, and I discuss my sins with my priest,” and began crying. Def. Facts ¶¶ 168, 169. Ms. Foster took Ms. Sievers’ hand and asked Ms. Sievers: “Is it okay if I pray over you?” Ms. Sievers testified that she was “totally offended” at the suggestion that Ms. Foster pray over her, but acquiesced only because she “was already in such hot water with my job.” Def. Facts ¶¶ 170,171. At the December 6 meeting, Ms. Foster told Ms. Sievers that if it were she, she would quit. Ms. Sievers told her that she did not intend to quit. PI. Add. Facts ¶¶ 1023, 1024. Ms. Foster concluded that Ms. Sievers was so devastated by the survey results and so torn by the damaged relationships in the office that it would have been unfair to put Ms. Sievers back in her old position. Def. Facts ¶¶ 174, 175. Accordingly, Ms. Foster told Ms. Steuer-wald that Ms. Sievers was not a candidate for leadership training. Def. Facts ¶ 178. Ms. Steuerwald decided not to return Ms. Sievers to the branch manager position. Instead, she offered her a quality assurance position. Def. Facts ¶¶ 179,180. On December 7, 1995, Ms. Sievers met with Ms. Foster, Darlene Wright (personnel director for the southern branches), and Sue Klein. During this meeting, Ms. Foster informed Ms. Sievers that she would not be reinstated to the branch manager position, but that the company was offering her a position in quality assurance. She was also informed that Sue Klein would become the new branch manager at Vincennes. The following week, Ms. Sievers’ demotion was formalized in a meeting with Ms. Klein, Ms. Wright, and Mr. Pyatt. Ms. Sievers accepted the quality assurance position at a reduced rate of pay. Her performance in the quality assurance position was always satisfactory. Def. Facts ¶¶ 181-184; PI. Add. Facts ¶¶ 1035,1039. On January 31, 1995, Ms. Sievers’ attorney, L. Edward Cummings, wrote a letter to Ms. Steuerwald questioning whether religion had played a part in Ms. Sievers’ demotion. The letter read in part: There was no secret ... that [Sondra Sievers] was a practicing Catholic and was not comfortable with some or even much of the religious materials and indoctrination which was provided to your employees. When you had a discussion with her critical of her performance, the materials provided her were clearly religious telling her to confess and repent. Subsequently, she was placed in a program, Leader in the Making, in which she sincerely attempted to perform to your and your company’s expectations so that she could return to her position as manager. As you know, the entire focus of the “Leader in the Making” was religious and her success or lack of success in the program related to how she characterized her relationship with Jesus Christ. She and Ms. Foster had a particular discussion involving something called the Lordship Ladder which was not to Ms. Foster’s satisfaction and the following day Ms. Sievers learned that she was no longer going to be returned to her position as branch manager. Def. Facts, ¶ 185; PI. Add. Facts ¶ 863. Slightly more than a month later, on March 8, 1996, Ms. Steuerwald terminated Ms. Sievers at a meeting which Mr. Pyatt also attended. Ms. Steuerwald opened the meeting by saying to Ms. Sievers: “I understand that you have some questions about your demotion and that you feel it has to do with religious discrimination.” Pl. Add. Facts ¶ 1052. The parties do not, of course, agree as to the reasons for Ms. Sievers’ termination. Preferred argues that the discharge was performance related. The EEOC argues that it was based on Ms. Sievers’ failure to conform to Ms. Steuerwald’s religious views. We defer our discussion of the underlying facts until the analysis portion of this entry. 3. Ellen Blice. a. Background. Ellen Blice began working at Preferred’s Vincennes facility in April 1994. She was discharged on February 14, 1996. Def. Facts ¶¶ 199, 269; PI. Add. Facts ¶ 1002. At the time of her hire, Ms. Blice had been a Registered Nurse for less than a year. She had worked as a student nurse extern in the emergency room at Wellborn Baptist Hospital from December 1992 to May 1993 and from then until October 1993 as a graduate nurse in Wellborn’s emergency room performing the duties of a registered nurse. On October 31, 1993, Ms. Blice received her license and became a RN. From October 31, 1993 until mid-April 1994, Ms. Blice worked as a registered nurse at Wellborn. At the time of her hire, Ms. Blice had not had home health care experience. Def. Facts and PI. Resp. ¶ 205. Ms. Blice received positive six-month and one-year performance evaluations prepared by Ms. Burke. Def. Facts ¶ 206. As a field nurse, Ms. Blice was responsible for coordinating total client care, which included conducting the initial assessment, determining what other services are appropriate (e.g., home health aids, therapists), and coordinating the client’s eventual discharge. To qualify for Medicare, a patient must have a skilled nursing need and must be homebound. Skilled nursing needs include the need for instruction from nurses on how patients were to care for themselves, monitoring the patient’s medication needs, and watching for changes in the patient’s condition. Def. Facts ¶¶ 210-212. Ms. Blice was a life-long Catholic. During her interview with Darlene Wright, Ms. Wright, personnel director for the southern branches, informed Ms. Blice that Preferred was a Christian company, but did not discuss religion on a personal level or ask Ms. Blice about her religion. Ms. Blice also interviewed with Barb Burke, who did not mention religion at all. Def. Facts ¶¶ 196, 199-203. Ms. Burke offered Ms. Blice a position and Ms. Blice accepted. Def. Facts ¶ 204. Although Ms. Blice expressed no offense about Preferred’s Christian values and mission statement, she was uncomfortable with management’s persistent use of prayer. She asked Sue Klein not to pray before giving her answers to questions of a professional nature. She also complained to another employee that she didn’t need Sue Klein’s prayers. PI. Resp. to Def. Facts ¶ 215. During the week preceding her termination on February 14, 1996, Ms. Blice told Sue Klein six times not to pray over her all the time. PI. Add. Facts ¶ 1076. Ms. Blice thought that it was inappropriate to have religiously-oriented documents placed in her mailbox and was offended by receiving such documents at work. PI. Add. Facts ¶¶ 1078, 1079; Def. Facts ¶ 229. Ms. Blice testified that on several occasions she received documents relating to religion, broken or unbroken spirits, Psalms, scriptures, and prayers. Def. Facts and PI. Resp. ¶ 232. Although Ms. Blice routinely discarded the materials, she told Ms. Klein that she did not want to receive such religious materials in her mailbox. She said: “I don’t need this stuff in my mailbox because I already know the truth.” Def. Facts and Pl. Resp. ¶ 231; Pl. Add. Facts ¶ 1080 and Def. Resp. Ms. Blice continued to receive the religious materials. Pl. Add. Facts ¶ 1081. Additionally, there was a prayer before each of the meetings that Jackie Steuer-wald conducted. During a meeting called Home Care 101, Ms. Steuerwald asked a series of questions and gave prizes to the individual who was the first to answer correctly. The correct answers to the questions at the Home Care 101 meeting usually were “Jesus,” “God” or “the Bible.” Ms. Blice testified that she was uncomfortable at the meeting. She thought it was a waste of time because Ms. Steuerwald spent too much time talking about religion and not enough about home care. Pl. Add. Facts ¶¶ 1068-1072; Def. Facts ¶ 219, 221. Similarly, Ms. Blice understood that devotions at the Vincennes facility were optional during Sondra Sievers’ management, but that, after Sue Klein became acting branch manager, Ms. Klein told her that she had to be at devotions because she needed to learn to be more humble. Ms. Blice did not attend devotions because they were contrary to her religious beliefs. Pl. Add. Facts ¶ 1082, 1083. On the day that she was terminated, Ms. Blice had been told to go to devotions. Pl. Resp. to Def. Facts ¶ 216. Ms. Blice perceived a change in the atmosphere at work after Sondra Sievers was demoted and Sue Klein was promoted to branch manager in November 1995. Prior to becoming branch manager, Sue Klein was complimentary of Ms. Blice’s work. After Ms. Klein and Karen Lemons became managers, the atmosphere in the office became more overtly religious. Pl. Add. Facts ¶¶ 1073, 1074. Before Sue Klein assumed the interim branch manager role, she had occasionally invited Ms. Blice to attend her church. Ms. Blice always declined, but was not offended by the offers, nor did she feel any pressure to accept them. Ms. Blice described her relationship with Ms. Klein before Ms. Klein’s promotion as “great.” After Ms. Klein assumed the managership, however, Ms. Klein always prayed before and after discussing any problem. When Ms. Blice was part of a group and the group was praying, she “just kinda sat there and let them pray.” Def. Facts ¶¶ 222-226; Pl. Add. Facts ¶¶ 1075. Ms. Klein told Ms. Blice that she needed more prayer in her life. Def. Facts and Pl. Resp. ¶ 234. She also told Ms. Blice that “attending devotions would be good for her to learn to become more humble” and that Ms. Blice had to be at devotions on Tuesday because she needed to learn to be more humble. Def. Facts and Pl. Resp. ¶ 235. Nevertheless, Ms. Blice continued to avoid devotions because they were contrary to her beliefs. Def. Facts ¶ 236; Pl. Add. Facts ¶ 1083. b. Events Leading to Ms. Blice’s Termination. On a Friday afternoon in November 1995, Ms. Blice received an order from Dr. Shelton to remove a patient’s catheter and to reinsert it some time over the weekend. Ms. Blice paged Donna Drew, who was the on-call nurse for the weekend. As the on-call nurse, Ms. Drew was supposed to visit patients on an as-needed basis over the weekend. Ms. Drew did not respond to Ms. Blice’s page. When Ms. Drew did not respond, Ms. Blice informed Karen Lemons, her supervisor, that she needed to see Ms. Drew. Ms. Lemons indicated that Ms. Drew had left for the day. Ms. Blice informed Ms. Lemons of the change in the patient’s condition, and Ms. Lemons said she would inform Ms. Drew of the change. Ms. Drew received a page at 9:57 a.m. concerning the catheter patient. Ms. Drew spoke with Dr. Shelton, at 10:08. Dr. Shelton told Ms. Drew that he left specific orders to replace the catheter if the client was unable to void. Ms. Drew talked to Ms. Blice about the situation by 11:27 a.m. She told Ms. Blice that she was with her daughter at a sporting event and could not leave to take care of the patient right then. Ms. Drew did not go to the patient’s house to replace the catheter until 1:30 p.m. Sue Klein, the Acting Branch Manager, believes that the optimal response would have been for Donna Drew to replace the catheter immediately. PI. Add. Facts, ¶¶ 1084-1099; Def. Facts ¶¶ 238-252. Throughout the morning, the patient did not complain of any discomfort and a home health aid was present in the patient’s home. Def. Facts ¶ 253. The patient was not pleased with Ms. Drew when she arrived; during Ms. Blice’s next regularly scheduled visit, the patient asked that Ms. Drew not come back. Def. Facts ¶ 257. The following Monday morning, Sue Klein, Ellen Blice and Karen Lemons met. Ms. Klein and Ms. Lemons instructed Ms. Blice to be certain to make direct contact with the on-call nurse in the future whenever a patient’s condition changed. Although Ms. Blice did not accept any responsibility for the catheter incident because she felt she had acted appropriately by informing the nursing supervisor, she apologized and indicated that she would give proper notification in the future. Toward the end of Ms. Blice’s employment, she attended a meeting with Sue Klein, Donna Drew, Karen Lemons, and Terry Jennings, At the end of the meeting, Ms. Blice was encouraged to be more humble, to look to God and things would be better and she wouldn’t have as much chaos in her life. On February 8, 1996, Ms. Blice received a formal verbal warning about the catheter incident. Donna Drew did not receive a formal verbal warning, nor was any corrective action form was put in her file regarding her role in the incident. PI. Add. Facts ¶¶ 1100-1105; Def. Facts ¶¶ 255, 256. In early February 1996, a surveyor from the State audited some of Preferred’s client charts based on a complaint received from the client involved in the catheter incident. As a result of the survey, Preferred received a deficiency for lack of communication in the area of “coordinating client care.” The state surveyor had found two charts where the primary nurse had failed to coordinate with the on-call nurse; one chart involved the catheter matter where Ms. Blice was the primary nurse, while the other chart, on which Ms. Drew was the primary nurse, involved a failure to communicate a medication change. In response to the State’s deficiency, Preferred was required to prepare a plan of correction. The plan included counseling both primary nurses involved on the appropriate procedure for communicating changes in a client’s condition. As the primary nurse involved in the catheter incident, Ms. Blice received a verbal warning for her part in the miscommunication. Def. Facts ¶¶ 262-267. Ms. Drew said she was not at fault over the incident. She did not receive any formal discipline and was not counseled about the incident until February 16, 1996, two days after Ms. Blice was terminated. PI. Add. Facts ¶¶ 1104-1105. Ms. Blice asked to speak with Ms. Steu-erwald about the verbal warning. Ms. Steuerwald came to Vincennes on February 14, 1996. At devotions that day, Ms. Steuerwald handed Ms. Blice a song sheet for the song beginning “He is a mighty God” and said “You need to sing this.” Ms. Blice did not sing the song. Ms. Steuerwald stared at Ms. Blice for the remainder of the devotions period. Def. Facts ¶¶ 269-272; PI. Add. Facts ¶¶1111-1116. Following the conclusion of the devotions, Ms. Blice met with Ms. Steuerwald, Sue Klein, and Terry Jennings. Sue Klein opened the meeting with prayer. Ms. Blice explained her disagreement with the verbal warning she had received. She also said that the state auditor had not seen the whole truth regarding the incident. Ms. Klein acknowledged that management had not shown the state auditor all of the information regarding the incident. Def. Facts ¶¶ 273, 274 (and Pl. Resp.), 275 (and Pl. Resp.). Preferred states that Ms. Steuerwald discovered during this meeting of February 14 that Ms. Blice had discharged a patient prematurely when the patient had been at risk for congestive heart failure. Ms. Steuerwald states that, had she known the facts surrounding the catheter patient earlier, she would have discharged Ms. Blice when she found out. Def. Facts ¶¶ 280-301. Preferred asserts that Ms. Blice was discharged because of Ms. Klein’s and Ms. Steuerwald’s assessment of her “performance” and “attitude.” Def. Facts ¶ 301, n. 4. Ms. Blice was terminated that day. 4. Suzanne Elder a. Background. Ms. Elder began work at Preferred’s Lawrenceville, Illinois facility in February 1993. She interviewed with Darlene Wright and Sondra Sievers. Religion was not discussed during her interviews. During her orientation, Ms. Elder reviewed the “Transfiguration of Preferred,” which she thought was “a joke” and that “it was kind of silly” to hand it out. Def. Facts ¶¶ 306, 309-313. She thought handing out the Transfiguration was unnecessary and inappropriate. Pl. Add. Facts ¶ 1127. Ms. Elder’s initial performance evaluation was good. When Ms. Sievers was promoted to the Vincennes facility, Ann Parker offered Ms. Elder the branch manager position at Lawrenceville, but Ms. Elder declined. Def. Facts ¶ 317 and Pl. Resp. She gave several reasons for declining, one of which was, according to Preferred, “having to allow devotions in the office and to attend meetings at the corporate office that would be opened with prayer.” Pl. Add. Facts ¶ 1128 and Def. Reply. In describing the branch manager position, Ann Parker told Ms. Elder that, as a branch manager, she would have to start having devotions in the Lawrenceville office. Pl. Add. Facts ¶ 1129. She also told Ms. Elder that, as a branch manager, when she visited the corporate office there would be devotions and prayer before meetings. Pl. Add. Facts ¶ 1130. Ms. Elder did not want to attend devotions because she thought it was inappropriate. It was no secret in the Lawrenceville office that Sondra Sievers and Suzanne Elder went to the same Catholic church. Pl. Add. Facts ¶¶ 1132,1133. Terry Jennings ultimately became the branch manager of the Lawrenceville office in July 1993, at which time devotions at Lawrenceville began. Ms. Jennings prepared Ms. Elder’s six-month performance evaluation, which was positive. Def. Facts ¶¶318, 319. Pl. Add. Facts ¶ 1131. After Ms. Jennings took over the branch operations, conflict developed between her and Ms. Elder. Ms. Jennings testified that she perceived Ms. Elder as being rude and disorganized. Ms. Elder thought that Ms. Jennings criticized her for everything from how she sighed, to when she went to lunch, to how she acted on the telephone, to how she interacted with the field nurses. Ms. Elder believes Ms. Jennings treated her in this manner because Ms. Elder is Catholic, although she never heard Ms. Jennings say anything negative about Catholics. Def. Facts ¶¶ 322-326. Ms. Elder testified that Darlene Wright was called in “to mediate the problems [between Ms. Elder and Ms. Jennings] and make me change.” Ms. Wright told Ms. Elder at these meetings to read the Bible and once attempted to conduct a laying of hands on her. Def. Facts and PI. Resp. ¶ 328. Ms. Wright prayed at the start of each meeting. Def. Facts and PI. Resp. ¶¶ 329. Ms. Wright discussed with Ms. Elder how to approach Ms. Jennings with a more open communication style and to be aware of how her body language was perceived. Ms. Wright also gave Ms. Elder some books to read on personality profiles and told Ms. Elder to read the Bible. Ms. Wright counseled her to show a constant verbal expression of her faith. Def. Facts and PL Resp. ¶¶ 330-332. Sometime after this meeting, Ms. Wright met with Ms. Elder and Ms. Jennings in an effort to resolve the conflict between them. Def. Facts ¶ 333. Ms. Elder testified that “supposedly the conflict was all on my fault, on my side, that I was the reason for the conflict and I was the one who had to change.” PI. Resp. to Def. Facts ¶ 333. Ms. Jennings presented Ms. Elder with a list of goals to meet by February 17, 1994. The goals included: (1) improving communications; (2) meeting with Ms. Jennings daily to discuss agendas; (3) following office protocols established by the branch manager; (4) limiting telephone calls to the corporate office to a designated time during the day; (5) focusing on time management; (6) communicating events to the appropriate staff person; and (7) displaying courtesy to other staff members. Ms. Elder thought these goals were unnecessary and were based on isolated incidents rather than patterns of behavior. Some of the goals she considered completely groundless. Def. Facts ¶ 335-337. Ms. Elder met several times with Ms. Wright one-on-one. Ms. Wright started each with prayer. During one of these meetings, Ms. Wright asked Ms. Elder if she had a Bible and said that Ms. Elder should read the Bible because it would help her become a better person. PI. Add. Facts ¶¶ 1144-1145. When Ms. Wright told Ms. Elder that she needed to show constant verbal expression of her faith, Ms. Elder felt that it was none of Ms. Wright’s business how she presented herself in her religious beliefs. At one of these meetings Ms. Wright said that laying on of hands would make Ms. Elder feel better. Ms. Elder was upset by the suggestion to do laying on of hands because it is contrary to her beliefs. PI. Add. Facts ¶¶ 1146-1147. Ms. Elder transferred from Lawrence-ville to Vincennes prior to February 14, 1994. Def. Facts ¶ 338. In Vincennes, Ms. Elder was primarily a field nurse, but performed quality assurance work as well. She did not experience harassment or religious discrimination in Vincennes while Sondra Sievers was her branch manager. Def. Facts ¶¶ 339, 340. On July 22, 1994, Ms. Elder