Action alleging violation of state & federal laws prohibiting discriminatory employment practices; Whether the First & Fourteenth Amendment prohibited review of plaintiff’s claims “because he performed important religious functions at” defendant’s school; The doctrine of ecclesiastical abstention & the “ministerial exception”; Our Lady of Guadalupe Sch v Morrissey-Berru; Conlon v InterVarsity Christian Fellowship

[This appeal was from the WD-MI.] The court affirmed the district court’s ruling that it could not adjudicate plaintiff-Pulsifer’s employment discrimination claims and was required to grant defendant-Westshore Christian Academy summary judgment under the doctrine of ecclesiastical abstention and the “ministerial exception.” Undisputed facts showed that his job included performing “vital religious duties to support the Academy’s religious mission[.]” Pulsifer, an African American, was the Dean of Students and Assistant Principal. His job duties required him to be a spiritual leader both in and out of school. He helped implement and lead religious youth groups, he did “a devotion with Academy staff each morning, and he frequently prayed over staff. He also prayed and led devotions at each meeting of the school’s board.” When the Academy fired him, he sued for discriminatory practices under federal and state law. The district court ruled that Pulsifer’s claims were barred by the ministerial exception, which provides that the First and Fourteenth Amendments prohibit applying “state and federal ‘laws governing the employment relationship between a religious institution and certain key employees.’” On appeal, the court considered whether Pulsifer was the type of employee covered by the exception. It concluded that “he was. Pulsifer played an important role in furthering the school’s mission to provide for the religious education and formation of students. Judicial review of the way in which the Academy chooses who should fill that type of role ‘would undermine the independence of religious institutions in a way that the First Amendment does not tolerate.’” The court explained that religious institutions have “‘autonomy with respect to internal management decisions that are essential to the institution’s central [religious] mission.’” It held that there was abundant evidence on the record that a vital part of Pulsifer’s job was to further the Academy’s religious mission. “Like the teachers in Our Lady of Guadalupe, Pulsifer was expected to guide his students’ spiritual formation by ‘express[ing] Christian values to students’ and being their ‘spiritual leader.’” In addition, he “performed a number of important religious functions.” The court noted that “an employee can fall within the ministerial exception even when ‘[m]ost’ of their ‘work [is] secular in nature’” as long as they perform certain types of religious duties.