South-Western Legal Studies in Business

Courts May Not Take Discrimination Suits That Fall Under Ministerial Exception

Appeals court held that due to First Amendment freedom of religion, federal courts are precluded from subject matter jurisdiction over employees of religious organizations who fall under the ministerial exception.


Employment Discrimination

Key Words

Disability; First Amendment; Ministerial Exception; Subject Matter Jurisdiction

C A S E   S U M M A R Y

Hollins worked for Methodist Hospital, which is operated “in accordance with the Social Principles of The United Methodist Church.” She worked in the clinical pastoral education program, which required her to initiate pastoral visits with patients and family members and to be on call as a chaplain for Methodist health facilities in the area. As the result of a psychiatric evaluation, Hollins was fired because, according to her complaint, she was “perceived as being a threat of harm” to the workplace. She sued for disability discrimination. The district court held for defendant, ruling that there was a ministerial exemption that applied to persons such as Hollins, so the court had no subject matter jurisdiction over the issue. Hollins appealed.


Affirmed. For the ministerial exception under the First Amendment to bar an employment discrimination claim, the employer must be a religious institution and the employee must have been a ministerial employee. The employer need not be a traditional religious organization such as a church. The ministerial exception precludes subject matter jurisdiction over claims involving the employment relationship between a religious institution and its ministerial employees based on the institution’s constitutional right to be free from judicial interference in the selection of those employees.


Hollins v. Methodist Healthcare, Inc., 474 F.3d 223 (6th Cir., 2007)

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