Dayner v. Archdiocese of Hartford, 301 Conn. 759

Patricia Dayner, long-time Catholic school principal, was not renewed for the 2005-2006 school year by the Archdiocese of Hartford and its pastor, after a history of performance criticisms and alleged coercive pressure to resign.
She had a formal performance review in 2004 and signed a contract for 2004-2005; she later faced repeated concerns and pressure from Bzdyra to resign or transfer.
In late 2004–early 2005, Dayner resisted coercive moves, informed Mann of concerns, and ultimately submitted a resignation that the archdiocese treated as a prelude to nonrenewal.
In 2005 she sought damages for breach of implied contract, good faith, promissory estoppel, public policy wrongful termination, and related tort claims; defendants moved to dismiss invoking ministerial exception.
The trial court denied the motion to dismiss; appellate review focused on whether the ministerial exception precludes judicial consideration of the secular claims against a religious employer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ministerial exception applies to bar the claims.	Dayner argues for a nuanced, noncategorical approach permitting review of nonreligious claims.	Archdiocese argues for strict Second Circuit Cote framework precluding such claims.	Yes; CT adopts the Second Circuit Cote approach to dismiss all claims.
Whether Dayner is a ministerial employee whose claims are barred.	Dayner is a ministerial employee; nonreligious claims still barred.	Dayner’s role as principal is inherently religious; claims barred.	Dayner is a ministerial employee; the ministerial exception bars the claims.
Whether Counts 1-3 (implied contract, good faith, promissory estoppel) are barred.	These arise from failure to follow archdiocese procedures.	Procedural failures tied to religious governance are barred.	Counts 1-3 barred by ministerial exception.
Whether Counts 4-6 (public policy wrongful termination, IIED, tortious interference) are barred.	Actions flow from termination decision; not about doctrine.	Dispute concerns church leadership decisions; would entangle church.	Counts 4-6 barred by ministerial exception.

Rweyemamu v. Cote, 520 F.3d 208 (2d Cir. 2008) (holistic, fact-based test; consider if adjudication intrudes on doctrine or governance)
McClure v. Salvation Army, 460 F.2d 553 (5th Cir. 1972) (ministry–church relationship as core ecclesiastical concern; court lacks jurisdiction over ministerial disputes)
Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC, 597 F.3d 769 (6th Cir. 2010) (primary duties test; analyzes function, not title, to determine ministerial status)