Lynn Starkey v. Roman Catholic Archdiocese of
No reporter citation yet (slip opinion) (2022)
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Rule of Law:
The First Amendment's ministerial exception, which bars judicial review of employment disputes involving religious organizations and their ministers, applies to both federal and state law claims that implicate ecclesiastical matters, focusing on what an employee is entrusted to do rather than solely on what they choose to perform.
Facts:
- Roncalli High School, a Catholic school within the Archdiocese of Indianapolis, operates with a mission to form Christian leaders and prioritizes hiring 'faithful Catholics' for teaching, administrative, and guidance counseling roles.
- Lynn Starkey began working at Roncalli in 1978, serving in various capacities including assistant band director, choral director, New Testament teacher, fine arts chair, and eventually a guidance counselor.
- From 2007 to 2017, Roncalli's employment contracts included a 'morals clause' requiring employees to avoid conduct or lifestyles inconsistent with Archdiocese policies or Catholic teachings, specifically listing cohabitation outside of legal marriage as a default.
- In May 2018, Starkey signed a 'School Guidance Counselor Ministry Contract' and an 'Archdiocese of Indianapolis Ministry Description,' which designated guidance counselors as 'ministers of the faith' responsible for 'facilitating faith formation,' and updated the morals clause to prohibit relationships 'contrary to a valid marriage as seen through the eyes of the Catholic Church' (defined as between a man and a woman).
- As Co-Director of Guidance, Starkey helped draft performance criteria for the guidance counselors she supervised, which included religious factors such as encouraging students' spiritual life and attending Sunday liturgy.
- Starkey served on Roncalli’s Administrative Council, which addressed both daily operations and the school’s spiritual life, and participated in discussions concerning the school's religious mission.
- In August 2018, Starkey informed Roncalli's leadership that she was in a same-sex union.
- At the end of her contract, Roncalli informed Starkey that her employment would not be renewed for the upcoming school year because her conduct violated the terms of her contract.
Procedural Posture:
- In July 2019, Lynn Starkey filed a complaint in the United States District Court for the Southern District of Indiana, Indianapolis Division, alleging Roncalli and the Archdiocese violated Title VII of the Civil Rights Act of 1964 and Title IX of the Education Amendments of 1972, as well as two Indiana state tort claims.
- Following discovery, the Title IX claims were dismissed.
- Roncalli and the Archdiocese moved for summary judgment based on the ministerial exception, Title VII's religious exemption, the Religious Freedom and Restoration Act of 1993, and other grounds.
- The District Court granted summary judgment for Roncalli and the Archdiocese based on the ministerial exception, without reaching the other issues.
- Lynn Starkey (Plaintiff-Appellant) appealed the District Court's decision to the United States Court of Appeals for the Seventh Circuit, with the Roman Catholic Archdiocese of Indianapolis, Inc. and Roncalli High School, Inc. as Defendants-Appellees.
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Issue:
1. Is a guidance counselor at a Catholic high school considered a minister under the First Amendment's ministerial exception when the school entrusts them with religious duties and holds them out as a minister? 2. Does the ministerial exception apply to state law tort claims, such as intentional interference with contractual relationship and intentional interference with employment relationship, when such claims implicate ecclesiastical matters?
Opinions:
Majority - Brennan, Circuit Judge
Yes, Lynn Starkey was a minister under the First Amendment’s ministerial exception, and the exception applies to both federal and state law claims that implicate ecclesiastical matters. The court affirmed the district court's conclusion, finding that Starkey was entrusted with communicating the Catholic faith to students and guiding the school's religious mission. As Co-Director of Guidance and a member of the Administrative Council, Starkey was a school leader responsible for Roncalli’s daily ministry and operations. Her responsibilities included leading prayer over the public address system, supervising other counselors whose roles involved faith formation, and helping develop religious criteria for their evaluation. Roncalli also held Starkey out as a minister, identifying her as a 'minister of the faith' in her job description and employing her under a 'Ministry Contract.' The court clarified that the ministerial exception focuses on what an employee is entrusted to do, not merely what they choose to perform, rejecting Starkey's argument that her non-participation in certain religious matters exempted her. Her claim that the 'Ministry Description' was pretextual was also rejected, finding it an honest formalization of her ongoing religious responsibilities. Regarding the state law claims, the court held that the ministerial exception applies to such claims, like those for breach of contract and tortious conduct, when they implicate ecclesiastical matters. This aligns with Supreme Court guidance in Hosanna-Tabor and Our Lady of Guadalupe, and the precedents of other circuits. Adjudicating Starkey’s state tort claims (Interference with Contractual Relationship and Intentional Interference with Employment Relationship) would require reviewing the Church’s authority over the employer-employee relationship and the contract’s contents, leading to excessive judicial entanglement in 'strictly ecclesiastical' matters. The court stressed that the exception protects religious organizations' autonomy in selecting and controlling ministers, but does not shield them from liability in non-ecclesiastical matters or for criminal/personal tort liability outside the scope of employment.
Concurring - Easterbrook, Circuit Judge
While concurring with the majority's conclusion that the ministerial exception barred the claims, Judge Easterbrook expressed concern that the court did not first address the statutory religious exemption in Section 702(a) of the Civil Rights Act of 1964 (42 U.S.C. § 2000e–1(a)). He argued that this statutory provision, coupled with the definition of religion in Section 2000e(j) (which includes 'all aspects of religious observance and practice, as well as belief'), provides a straightforward basis for resolving the Title VII claims. He contended that Roncalli, as a religious educational institution, was entitled to fire Starkey without regard to Title VII's substantive rules because its decision was based on its theological views regarding same-sex marriage. He critiqued the common judicial interpretation that Section 702(a) permits only religious discrimination but no other kind, asserting that when an employment decision is genuinely founded on religious beliefs, all of Title VII should be inapplicable. He noted that while Bostock holds that firing based on same-sex partners is sex discrimination, it is also religious discrimination if based on theological views, and Section 702(a) permits religious employers to require staff to abide by religious rules and serve as role models.
Analysis:
This case significantly broadens the application of the ministerial exception, affirming its extension to state law tort claims when they implicate ecclesiastical matters. By emphasizing 'what an employee is entrusted to do' over 'what an employee chooses to perform,' the decision solidifies religious institutions' autonomy in ministerial employment decisions, preventing employees from unilaterally opting out of ministerial status. This ruling reinforces the judiciary's commitment to avoiding entanglement in internal church governance, even when religious expectations are formalized in contracts after long-term employment. It provides greater certainty for religious organizations regarding the scope of their First Amendment protections in employment disputes across both federal and state legal landscapes.
