Alyce Conlon v. InterVarsity Christian Fellowship
777 F.3d 829
6th Cir.2015Background
- IVCF is a faith-based religious organization employing Conlon as a spiritual director from 1986 onward.
- Conlon informed her supervisor in March 2011 that she was considering divorce; she was placed on paid then unpaid leave.
- Conlon was terminated December 20, 2011 for alleged failure to reconcile her marriage.
- Plaintiff alleged gender-discrimination claims under Title VII and Michigan Elliott-Larsen Act; defendants asserted ministerial exception.
- District court dismissed the case, holding the ministerial exception barred all claims; the Sixth Circuit affirmed on appeal.
- Hosanna-Tabor established the ministerial exception; this decision analyzes its application to Conlon’s claims against a religious employer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ministerial exception applies to Conlon’s claims | Conlon contends exception does not apply to her case | IVCF argues exception applies to ministerial employee | Yes; ministerial exception applies to Conlon’s ministerial position |
| Whether IVCF is a religious organization capable of asserting the exception | IVCF’s status is not religious enough to invoke exception | IVCF is a religious group with Christian mission | IVCF qualifies as a religious organization for ministerial exception purposes |
| Whether the ministerial exception can be invoked to bar state-law claims | Michigan law claims should be barred only by state law | Establishment/Free Exercise Clauses apply; exception bars both federal and state claims | Yes; both federal Title VII and Michigan state-law claims are barred |
| Whether supervisors can be liable when the ministerial exception applies | Supervisors could be liable independently | Individual supervisors cannot be liable when exception applies to employer | Supervisors cannot be held liable under Michigan law in this context |
Key Cases Cited
- Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC, 565 U.S. 171 (2012) (ministerial exception applies to employment-discrimination claims against religious employers)
- Hollins v. Methodist Healthcare, Inc., 474 F.3d 223 (6th Cir. 2007) (min. exception applies to religious organizations; waiver limited post-Hosanna-Tabor)
- Sambo’s Restaurants, Inc. v. Ann Arbor, 663 F.2d 686 (6th Cir. 1981) (waiver/estoppel considerations in ministerial exception context (pre-Hosanna-Tabor))
- Kedroff v. St. Nicholas Cathedral of Russian Orthodox Church in N.A., 344 U.S. 94 (1952) (establishment/free-exercise considerations underpin ministerial protections)
- Weishuhn v. Catholic Diocese of Lansing, 279 Mich. App. 150 (2008) (Michigan recognizes ministerial exception in state law)