In Uzomechina v. Episcopal Diocese of New Jersey, 2024 WL 4336974 (D.N.J. Sept. 26, 2024), the court applied the “ministerial exception” to dismiss plaintiff’s race-based discrimination claim asserted under 42 U.S.C. § 1981.
From the decision:
With respect to Plaintiff’s sole federal claim under Section 1981, the Diocese Defendants argue that the “[ministerial] exception operates as an affirmative defense” barring the claim. The Court agrees.
The ministerial exception is a recognition of “the right of churches and other religious institutions to decide matters ‘of faith and doctrine’ without government intrusion.” Our Lady of Guadalupe Sch. v. Morrissey-Berru, 591 U.S. 732, 746 (2020) (quoting Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171, 186 (2012)). For decades, the Supreme Court has recognized that “hierarchical religious organizations [are permitted] to establish their own rules and regulations for internal discipline and government, and to create tribunals for adjudicating disputes over” such matters. Serbian E. Orthodox Diocese for the U.S. & Canada v. Milivojevich, 426 U.S. 696, 724 (1976). Later, the exemption was expanded to include “employment[-related] discrimination suit[s] brought on behalf of a [church-employed] minister.” Hosanna-Tabor, 565 U.S. at 196; see also Our Lady of Guadalupe, 592 U.S. at 737 (describing the holding in Hosanna-Tabor as adopting the ministerial exception “to laws governing the employment relationship between a religious institution and certain key employees.”). Accordingly, to assess whether the ministerial exception applies, the Court need only look to whether on the face of the Amended Complaint Plaintiff: (1) alleges that he was a “minister” employed by the Diocese Defendants; and (2) brings an employment-related discrimination claim against the Diocese Defendants.
First, Plaintiff clearly alleges he was a “minister” employed by the Diocese. (See generally Am. Compl.) The Amended Complaint affirms that Plaintiff “is a pastor” and “priest,” holds religious degrees from seminaries, and “used spiritual principles” and “spirit-filled leadership” in his “positive ministry” to “at-risk young men.” The Court, therefore, finds that Plaintiff’s position is that of a “minister” for purposes of the First Amendment. See Hosanna-Tabor, 565 U.S. at 191-93 (considering a plaintiff’s duties, religious education, ordained status, and whether one is held out as a minister in assessing their ministerial status and concluding that even a “teacher” may, under the appropriate circumstances, constitute a “minister” for purposes of the ministerial exception); id. at 199 n.1 (clarifying that a “pastor” or “priest” like that which Plaintiff alleges he previously was for the Diocese is a “minister” within the meaning of the ministerial exception where “many persons who clearly fall within the ‘ministerial’ exception” include “Protestant ministers, Catholic priests, and Jewish rabbis”); Morrissey-Berru, 591 U.S. at 758 (calling “on courts to take all relevant circumstances into account … to determine whether each particular position implicated the fundamental purpose of the exception”).
Second, having established Plaintiff was a minister while employed by the Diocese Defendants, the Court then must assess whether Plaintiff’s Section 1981 claim is predicated on employment discrimination. If so, the ministerial exception applies against the claim.
Importantly, Plaintiff himself describes his Section 1981 claim as a “discrimination and retaliation” claim against his employer. (Pl.’s Opp’n Br. 8) (“Plaintiff … has … alleged sufficient facts to state a plausible discrimination and retaliation claim under 42 [U.S.C. §] 1981.”) Moreover, the Amended Complaint is undeniably predicated on allegations related to his employment relationship with a church, i.e., the Diocese. (See, e.g., Am. Compl. ¶ 22 (stating that the Diocese Defendants falsely charged Plaintiff “with misconduct” under the “Episcopal Cannons”); ¶ 29 (alleging that the Diocese Defendants “conspired against him based on racially motivated false allegations” made internally by members of the Diocese).) The employment relationship between Plaintiff and the Diocese Defendants, as governed by Section 1981, is exactly the sort of relationship that the Supreme Court has cautioned is subject to the ministerial exception. Our Lady of Guadalupe, 591 U.S. at 767 (clarifying that there exists a “ ‘ministerial exception’ to laws governing the employment relationship between a religious institution and certain key employees.”); see also CBOCS W. v. Humphries, 553 U.S. 442, 448 (2008) (noting Congress’s focus on bolstering employment discrimination protections when revising 42 U.S.C. § 1981 so that it could be utilized to sustain employment discrimination claims); Serbian E. Orthodox, 426 U.S. at 724 (“[H]ierarchical religious organizations [are permitted] to establish their own rules and regulations for internal discipline and government.”) Plaintiff’s Section 1981 claim against the Diocese Defendants, despite his protestations to the contrary, is an employment discrimination claim subject to the ministerial exception where he alleges false statements were made against him pursuant to the “Episcopal Canons” which he alleges: (1) were racially motivated; (2) led to employment related consequences; and (3) were impermissible under his employment contract with the Diocese Defendants. As such, and because the ministerial exception is an affirmative defense, the Court dismisses Count I of Plaintiff’s Amended Complaint with prejudice.
[Citations and internal quotation marks omitted.]
The court further declined to exercise supplemental jurisdiction over plaintiff’s state-law claims, reasoning that since it denied plaintiff’s sole surviving federal claim with prejudice, and there were no principles of judicial economy, convenience, or fairness warranting a contrary conclusion.