Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC

Teacher at a religious elementary school was barred from asserting an employment discrimination suit on the basis of the ministerial exception.

The Equal Employment Opportunity Commission (“EEOC”) filed a claim against a Church as a result of the firing of one of its “lay” or voluntary teachers that was suffering from narcolepsy. The lawsuit by the EEOC alleged various employment based violations including among others, the Americans with Disability Act (“ADA”). Although such teachers were considered “lay” or volunteers, in order to accept callings for such teaching positions, individuals were required to complete a number of academic courses including specifically a course on theological studies. At trial, the case asserted by the EEOC was dismissed on summary judgment where the Church has asserted a ministerial exception, a constitutional doctrine based on the First Amendment of the U.S. Constitution.

The Court of Appeals for the Sixth Circuit vacated the trial court’s granting of summary judgment, including the recognition of the existence of a ministerial exception, but in this particular case, concluded that Plaintiff did not qualify as a minister under the exception, especially where Plaintiff performed the same religious duties as a lay teacher, and there was no differentiation between a minister and a lay teacher.

In reviewing the Sixth Circuit Court of Appeals Case, the Court unanimously reversed, holding in pertinent part that the Church was in fact entitled to the defense under the ministerial exception and therefore Plaintiff was barred from asserting such ADA based claims. As reasoned by the U.S. Supreme Court, the ministerial exception is grounded in First Amendment jurisprudence and therefore, as such, the Church could not be subjected to any application of employment discrimination legislation concerning the employment relationship between a religious institution and its ministers. Further the Court reasoned that if Churches were to be subjected to state imposed employment discrimination claims, the State would essentially be imposing upon such Churches a requirement that would constitutionally infringe upon the Free Exercise Clause, in particular the ability of Churches to refuse to hire unwanted ministers, the religious group’s right to shape its own faith and mission through its appointments, and the prohibition of government involvement in ecclesiastical matters. Applying the facts of the case, the Supreme Court held that the ministerial exception applied to the plaintiff teacher because the Church held her out as a minister, with a role that was entirely distinct from that of most of its members, and therefore, her title as a minister reflected a significant degree of religious training followed by a formal process of commissioning. As such, in this particular case, the Court determined that since the Plaintiff herself had even held herself out as a minister of the Church by accepting the formal call to serve in a religious capacity and acknowledged that her job duties similarly reflected a role in conveying the Church’s message and carrying out its mission, that the Plaintiff could not then seek to limit such ministerial defense in this regard.

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