Supreme Court upholds ADA ministerial exception

[JURIST] The US Supreme Court [official website] ruled unanimously [opinion, PDF] Wednesday in Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC [SCOTUSblog backgrounder] that the Establishment and Free Exercise Clauses [Cornell LII backgrounders] of the First Amendment bar wrongful termination lawsuits when the employer is a religious group and the employee is one of the organization's ministers. The Americans with Disabilities Act (ADA) [text] contains a "ministerial exception" that allows religious organizations to give "preference in employment to individuals of a particular religion" and to "require that all applicants and employees conform to the religious tenets of such organization." The Equal Employment Opportunity Commission (EEOC) [official website] and Cheryl Perich brought a claim against the Hosanna-Tabor Evangelical Lutheran Church and School alleging that the school had unlawfully terminated Perich in violation of the ADA because she was diagnosed with narcolepsy. The US Court of Appeals for the Sixth Circuit held [opinion, PDF] that the school violated the ADA and that the ministerial exception did not apply. In reversing the appeals court, Chief Justice John Roberts articulated the purpose of the ministerial exception:

The members of a religious group put their faith in the hands of their ministers. Requiring a church to accept or retain an unwanted minister, or punishing a church for failing to do so, intrudes upon more than a mere employment decision. Such action interferes with the internal governance of the church, depriving the church of control over the selection of those who will personify its beliefs. By imposing an unwanted minister, the state infringes the Free Exercise Clause, which protects a religious group's right to shape its own faith and mission through its appointments.
The court ultimately concluded that the ministerial exception applied in Perich's case given the circumstances of her employment.

Justice Clarence Thomas wrote separately to emphasize the deference courts must give to a "religious organization's good-faith understanding of who qualifies as its minister." The other justices implemented a fact-intensive analysis to determine whether the employee was a "minister" and therefore subject to the ministerial exception.

 

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