Kelley v. Decatur Baptist Church, 5:17-cv-01239

Kelley worked for Decatur Baptist Church as a maintenance and childcare employee from March 17, 2015 to August 27, 2015 and notified the employer she was pregnant during the summer of 2015.
Decatur Baptist terminated Kelley on August 27, 2015; Kelley alleges the termination was because of her pregnancy and filed a Title VII pregnancy discrimination claim with the EEOC (which issued a finding for Kelley).
Church pastor Danny Holmes and the daycare director provided affidavits stating Kelley was discharged for sexual conduct outside marriage and sowing discord—religious-grounded reasons the church says justify the discharge.
Decatur Baptist moved to dismiss under Rule 12(b)(1) (ecclesiastical abstention) and Rule 12(b)(6) (ministerial exception), arguing First Amendment protections bar adjudication.
The court found disputed factual issues about the true reason for termination (pregnancy discrimination vs. religious misconduct) and denied dismissal, allowing discovery and requiring an answer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ecclesiastical abstention deprives the court of subject-matter jurisdiction	Kelley: disputed facts; termination was pregnancy-based, so secular adjudication is permitted	Decatur Baptist: adjudication would require resolving religious doctrine/discipline, so abstention applies	Denied under 12(b)(1): factual dispute requires discovery; court cannot resolve abstention now
Whether the ministerial exception bars the Title VII claim	Kelley: she was a maintenance/childcare worker, not a minister; exception does not apply	Decatur Baptist: Kelley functioned as a minister (training/evangelizing children), so exception applies	Denied under 12(b)(6): complaint does not on its face show ministerial exception; factual issues exist
Whether the ministerial exception is jurisdictional or an affirmative defense	Kelley: ministerial exception should not automatically bar suit	Decatur Baptist: exception precludes claims against ministers	Court: ministerial exception is an affirmative defense, not jurisdictional; cannot dismiss on face of complaint
Whether discovery/hearing are required before resolving First Amendment defenses	Kelley: factual development needed to test church's stated reasons	Decatur Baptist: seeks early dismissal	Court: factual challenge to jurisdiction requires permitting discovery and appropriate hearing before dismissal

Watson v. Jones, 80 U.S. 679 (establishes church autonomy principle and limits civil adjudication of ecclesiastical matters)
Serbian E. Orthodox Diocese v. Milivojevich, 426 U.S. 696 (civil courts must not resolve ecclesiastical questions of doctrine and church governance)
Hosanna–Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (recognizes the ministerial exception as protecting a church’s selection/control of its ministers)
Crowder v. Southern Baptist Convention, 828 F.2d 718 (11th Cir.) (describes scope of ecclesiastical abstention and limits on secular review)
McElmurray v. Consolidated Government of Augusta–Richmond County, 501 F.3d 1244 (11th Cir.) (distinguishes facial vs. factual 12(b)(1) attacks and requires discovery for factual challenges)
Jones v. Wolf, 443 U.S. 595 (permissible use of neutral principles in some church property disputes)
Ohio Civil Rights Comm’n v. Dayton Christian Schools, 477 U.S. 619 (investigations allowed to determine if religious justification is pretext)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for Rule 12(b)(6) plausibility)