Ministerial Exception Doctrine Applies Categorically to Hostile Work Environment Claims

Religion Clause ^ | 12/14/22 | Howard Friedman

[marshmallow]

In Rivera v. Diocese of Venice in Florida, Inc., (SD FL., Dec. 12, 2022), a Florida federal district court dismissed under the ministerial exception doctrine a suit by the former principal of a Catholic elementary/ middle school who alleged that a racially motivated hostile work environment led him to resign his position. Plaintiff, who is black, was repeatedly the subject of racial harassment by the priest of the school's parish. The court said in part:

The principal question presented is whether the ministerial exception categorically bars hostile work environment claims under Title VII and FCRA. As further explored below, this is an issue of constitutional interpretation not yet specifically addressed by the Eleventh Circuit....

[T]he Court concludes that the ministerial exception categorically bars Plaintiff's hostile work environment claims....

To determine whether a minister's claim of hostile work environment proceeds based on the degree to which a court believes the fact-specific allegations require excessive entanglement with a church's internal governance is itself to promote and risk excessive entanglement and interference with a church's authority to supervise and manage its ministers. Put another way, the reason why a functional approach is necessary to resolve the threshold question of "minister status" is also one of the reasons why applying the ministerial exception to claims of hostile work environment is necessary to respect the First Amendment.

[Fido969]

Maybe the plaintiff should put on some big boy pants.