Ministerial Exception

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In Boliak v. Father Michael P. Reilly et al, No. 153941/16, 2025 WL 3672342 (N.Y. App. Div. 1 Dept. Dec. 18, 2025), the court, inter alia, held that the lower court improperly dismissed plaintiff’s hostile work environment claims under the “ministerial exception.” From the decision: Plaintiffs Boliak, Maureen Smith, and Thomas Rodes were all employed…

Read More Hostile Work Environment Claims Not Barred by the “Ministerial Exception”, First Department Holds
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In Sander v. Westchester Reform Temple, 2025 NY Slip Op 06958 (N.Y. Ct. Appeals Dec. 16, 2025), the New York Court of Appeals held that plaintiff’s discrimination claim was barred by the “ministerial exception.” From the decision: Plaintiff Jessie Sander alleges that she was fired from her teaching position at Westchester Reform Temple for co-authoring…

Read More NY Court of Appeals Holds “Ministerial Exception” Bars Plaintiff’s Discrimination Claim; Declines to Rule on Scope of “Recreational Activities” Discrimination Statute
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In Ibhawa v New York State Division of Human Rights, No. 100, 2024 N.Y. Slip Op. 05872, 2024 WL 4884944 (N.Y., Nov. 26, 2024), the New York Court of Appeals held that the the First Amendment’s “ministerial exception” did not deprive the New York State Division of Human Rights (DHR) of jurisdiction over the employee’s…

Read More Hostile Work Environment Claim’s Dismissal Per “Ministerial Exception” Was Erroneous, NY Court of Appeals Holds
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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…

Read More Applying “Ministerial Exception,” Court Dismisses Plaintiff’s Race Discrimination Claim
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In Montgomery v. St. John’s United Church of Christ, 2023 WL 2820472 (Ohio App. 5 Dist., 2023), the court upheld a lower court decision dismissing, pursuant to the “ministerial exception”, plaintiff’s sexual harassment hostile work environment claim. From the decision: The circuits are split on whether the ministerial exception categorically bars courts from considering a…

Read More Sexual Harassment Hostile Work Environment Claim Barred by “Ministerial Exception”
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In Brandenburg, Elizabeth et al v. Greek Orthodox Archdiocese of North America et al, 2023 WL 2185827 (S.D.N.Y. Feb. 23, 2023), the court addressed the following question, which has divided various courts: “whether, and under what circumstances, a clergy member can bring a claim for hostile work environment discrimination or retaliation against a religious employer.”…

Read More Nuns’ Hostile Work Environment Sexual Harassment Claims Survive Summary Judgment Against Greek Orthodox Archdiocese of North America; “Ministerial Exception” Did Not Bar Claims
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In a recent case, Demkovich v. St. Andrew the Apostle Parish, 19-cv-2142 (7th Cir. August 31, 2020), the U.S. Court of Appeals for the 7th Circuit[1]Note: This firm does not engage in the practice of law, and its owner is not licensed to practice law, in the jurisdiction which issued this decision. held that plaintiff’s…

Read More 7th Circuit: Hostile Work Environment Claim Not Barred by “Ministerial Exception”
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In Our Lady of Guadalupe School v. Morrissey-Berru, 2020 WL 3808420 (U.S. July 8, 2020), the U.S. Supreme Court expanded the so-called “ministerial exception” to employment discrimination claims. From the decision: In the cases now before us, we consider employment discrimination claims brought by two elementary school teachers at Catholic schools whose teaching responsibilities are…

Read More SCOTUS Expands “Ministerial Exception” to Employment Discrimination Claims
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In Penn v. New York Methodist Hospital, 2018 WL 1177293 (2d Cir. March 7, 2018), the Second Circuit affirmed the dismissal of plaintiff’s race and religious discrimination claims asserted under Title VII of the Civil Rights Act of 1964. From the Opinion: [T]he district court did not err in applying the ministerial exception doctrine. While a…

Read More Citing the “Ministerial Exception,” 2d Circuit Affirms Dismissal of Title VII Race/Religious Discrimination Claim
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In Stabler v. Congregation Emanu-El of the City of New York, No. 16 CIV. 9601 (RWS), 2017 WL 3268201 (S.D.N.Y. July 28, 2017), the court denied defendants’ motions to dismiss plaintiff’s claims of (e.g.) age discrimination, disability discrimination, and hostile work environment. Defendants based their motion to dismiss on the “ministerial exception”. The court summarized the…

Read More Hostile Work Environment And Other Claims Survive Dismissal on Basis of the “Ministerial Exception”
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