In Hosanna-Tabor Evangelical Lutheran Church and School v. Equal Employment Opportunity Commission, 132 S. Ct. 694 (2012), the United States Supreme Court ruled in favor a religious organization being sued by a former teacher.  There, a former employee filed a charge with the E.E.O.C. claiming that her employment had been terminated in violation of the Americans with Disabilities Act.  The E.E.O.C. brought suit against Hosanna-Tabor, alleging that the teacher had been fired in retaliation for threatening to file an ADA lawsuit.  The teacher intervened in the litigation.  Invoking what is known as the “ministerial excep­tion,” Hosanna-Tabor argued that the suit was barred by the First Amendment because the claims concerned the employment relation­ship between a religious institution and one of its ministers.  The District Court agreed and granted summary judgment in Hosanna­-Tabor’s favor.  The Sixth Circuit vacated and remanded.  It recog­nized the existence of a ministerial exception rooted in the First Amendment, but concluded that the teacher did not qualify as a “minister” under the exception. The Supreme Court disagreed.

The U.S. Supreme Court unanimously held that the Establishment and Free Exercise Clauses of the First Amendment bar suits brought on behalf of ministers against their churches claiming termination in violation of employment discrimi­nation laws.  Moreover, it held that the minis­terial exception to employment discrimination claims was applicable.  Looking at the facts, the Court noted that Hosanna-Tabor held the teacher out as a minister, she was issued her a “diploma of vocation,” her title was “Minister of Religion, Commissioned,” she had a significant degree of religious training followed by a formal process of commissioning, she held herself out as a minister of the Church, she had ministerial duties, and her job reflected a role in conveying the Church’s message and carrying out its mission.  For these and other reasons, she was considered a minister within the meaning of the minis­terial exception.  As such, the First Amendment required dismissal of the em­ployment discrimination suit against her religious employer.

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