Federal Court Refines Claims Subject to “Ministerial Exception”

The “ministerial exception” to laws governing employment relationships in the U.S. prevents courts from considering employment-related legal claims made by church employees, or former employees, who meet the definition of a “minister.” Our Lady of Guadalupe School v. Morrissey-Berru, 140 S. Ct. 2049 (2020); Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, 565 U.S. 171 (2012). The exception encourages churches to resolve employment disputes internally rather than in court (which is in keeping with I Corinthians 6:1-8), and prevents courts from delving into ecclesiastical details that could impinge on First Amendment religious freedoms. Do all claims from a former church minister fall within the ministerial exception? A federal district court in New Jersey ruled yesterday that, while claims of wrongful discharge and racial discrimination are barred by the ministerial exception, a claim of defamation is not.

The case, Uzomechina v. Episcopal Diocese of New Jersey (D NJ No. 3:2023cvo2914, Jan. 18, 2024), involves an African-American Episcopal priest who was discharged by the Diocese for financial and sexual misconduct. The priest then obtained a job at a drug addiction clinic, but claims that Diocesan officials published false statements about him so that the drug clinic dismissed him as well. The priest, Gideon A. Uzomechina, then sued the Episcopal Diocese and the drug clinic for wrongful discharge based on race discrimination, breach of contract, and defamation. The Diocese argued that the “ministerial exception” required the court to dismiss the case. There was no dispute here that the plaintiff fit the legal definition of a “minister.”

The federal court cited numerous cases that have dismissed claims of racial discrimination and wrongful discharge based on the ministerial exception in dismissing those claims in this case as well.

As to the defamation claim, the court noted that, while courts typically bar tort claims that arise from an internal church disciplinary process where the alleged defamation occurred within the church, the alleged defamation in this case occurred to non-church members (the drug clinic staff). The court determined that the Diocese, by sharing its internal disciplinary procedures and beliefs with a third party, subjected itself to a tort claim. Nevertheless, the court found in this case that the plaintiff had failed to plead sufficient facts to support a valid claim, and dismissed all the claims against the drug clinic on the same ground.

The ministerial exception is an important component of religious freedom, and courts will continue to wrestle with its applicability to messy church employment situations.