In 1991, the Equal Employment Opportunity Commission (EEOC) brought suit against Kamehameha Schools alleging that its requirement that all teachers be Protestant was religious discrimination in violation of the Civil Rights Act of 1964. Although Kamehameha Schools conceded the practice was discriminatory, the School maintained that it was bound by the provisions of Bernice Pauahi Bishop's will, which established the charitable trust creating the School as well as mandating that all the teachers "be persons of the Protestant religion." Accordingly, the School sought to be included within one of the applicable exemptions to the Civil Rights Act of 1964.