The Connecticut Supreme Court today ruled (in a decision that will be effective August 2, 2011) that the ministerial exception found under the First Amendment bars certain employment related claims brought against religious institutions.
The court’s unanimous decision in Dayner v. Archdiocese of Hartford can be downloaded here.
In doing so, the Court explicitly adopts the rule found in the Second Circuit in Rweyemamu v. Cote — a case I discussed back in 2008 here.
That rule requires a court to consider whether: “1) the employment relationship is religious in nature; and 2) if so, whether adjudicating the particular claims and defenses in the case would require the court to intrude into a religious institution’s exclusive right to decide matters pertaining to doctrine or its internal governance or organization. ”
In this case, the court said that the claims must fail. Victory to the religious employer.
For religious institutions in the state, this case is a must read and will clarify the standards that will (or will not) apply to reviewing employment decisions it makes. The case — which concerns the dismissal of a religious school principal — will have a more wide-ranging impact than you must first think about.
The case applies to ministerial exception to more than simply discrimination-type claims. Rather, the court applied it equally to common-law tort and contract claims as well.
The case has a lot of interesting tidbits – including some buried in footnotes — and I hope to point out a few of them in an upcoming post. Until then, religious institutions in the state have some new required reading.