A federal magistrate judge in Erie has allowed a Title VII sexual harassment case to proceed against the Roman Catholic Diocese of Erie and two of its parishes, ruling that discovery is needed to determine whether the three entities together constitute a “single employer” for the purposes of the litigation.

U.S. Magistrate Judge Susan Paradise Baxter of the Western District of Pennsylvania ruled June 16 in Clement v. The Roman Catholic Diocese of Erie that plaintiff Kathleen A. Clement sufficiently alleged that she was subject to an “offensively sexual hostile work environment” and constructively discharged from her position as a facilitator of religious education programs at three parishes in the diocese.

Clement had alleged that defendants St. Joseph and St. Michael the Archangel Parishes, along with the diocese, failed to address ongoing inappropriate sexual conduct by parish priest the Rev. Daniel Kresinski.