In a 9-0 decision yesterday, the Supreme Court reversed the Sixth Circuit and affirmed a religious body’s right to make employment decisions free from government intervention. It was the Supreme Court’s first decision on the ministerial exception to employment discrimination laws.
The plaintiff was a “called teacher” within the Lutheran Church, where part of her job included teaching religion and leading chapel services. After being diagnosed with a sleep disorder and taking a leave of absence, the church refused to reinstate her. The plaintiff sued, and the Sixth Circuit ultimately sided with the plaintiff on appeal. Because plaintiff’s religious duties only occupied 45 minutes of her day, the Sixth Circuit held that the ministerial exception to employment discrimination laws did not apply.
But in a majority opinion by Chief John Roberts, the Supreme Court reversed and noted that the issue was not one that could be “resolved with a stopwatch.” Instead, the Court looked to several factors. The plaintiff received her “call” after “a significant degree of religious training followed by a formal process of commissioning.” She “held herself out as a minister,” and claimed “a special housing allowance on her taxes that was available only to employees earning their compensation ‘in the exercise of the ministry.'” Her job gave her “a role in conveying the Church’s message and carrying out its mission.” She was fired, the school said, for violating religious doctrine by pursuing litigation rather than trying to resolve her dispute within the church. “Given all the circumstances of her employment,” the plaintiff fell within the ministerial exception. However, the Supreme Court gave only limited guidance about how courts should decide who counts as a minister, saying it was “reluctant to adopt a rigid formula.”
The Supreme Court ultimately found the balance in favor of the church’s protected ability to make its own decisions. The Court’s ruling will undoubtedly have significant consequences for countless people employed by religious groups to perform religious work. “The interest of society in the enforcement of employment discrimination statutes is undoubtedly important. But so too is the interest of religious groups in choosing who will preach their beliefs, teach their faith, and carry out their mission,” Roberts wrote. “The First Amendment has struck the balance for us,” Roberts continued. “The church must be free to choose those who will guide it on its way.”