Mealey's (March 20, 2019, 9:40 AM EDT) -- SAN FRANCISCO — Title VII of the Civil Rights Act of 1964’s religious organization exemption (ROE) is nonjurisdictional and subject to procedural forfeiture; however, without a showing that a delay in raising it as defense caused prejudice, ROE bars retaliation and hostile work environment claims by a former employee of the Salvation Army, a Ninth Circuit U.S. Court of Appeals panel ruled March 18 (Ann Garcia v. Salvation Army, No. 16-16827, 9th Cir., 2019 U.S. App. LEXIS 7993)....