Kristen Biel v. St. James School
911 F.3d 603
9th Cir.2018Background
- Kristin Biel was a fifth-grade teacher at St. James Catholic School (one year full-time) who taught secular subjects and a 30-minute religion class four days a week using a school-prescribed Catholic workbook. She participated in school prayers and attended monthly Mass with her class but did not lead prayers or plan Masses.
- Biel informed the school she had breast cancer and would need time off for treatment; the principal later declined to renew her contract, citing classroom-management concerns. Biel sued under the ADA alleging disability discrimination.
- St. James moved for summary judgment invoking the First Amendment ministerial exception; the district court granted summary judgment for St. James. Biel appealed.
- The Ninth Circuit majority applied the totality-of-the-circumstances test from Hosanna‑Tabor, finding Biel lacked many hallmarks of a “minister” (no ministerial title, training, or self‑identification as a minister) and that her religious duties were limited, so the ministerial exception did not bar her ADA claim.
- The Ninth Circuit reversed and remanded for further proceedings; a dissent would have affirmed, concluding Biel’s contractual commitments, handbook expectations, and classroom religious functions made her a minister under the exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ministerial exception bars Biel’s ADA claim | Biel was an ordinary teacher whose limited classroom religious duties do not make her a minister; exception should not apply | St. James: Biel’s role in teaching religion and contractual/handbook obligations render her a minister, so courts cannot adjudicate her ADA claim | Majority: Exception does not apply on these facts; reversed and remanded |
| How to apply Hosanna‑Tabor factors | Focus on functional limits of Biel’s religious duties and lack of ministerial indicia | Emphasize contractual language, handbook, and educational role transmitting faith | Majority: weigh all factors; only religious‑functions factor favors St. James; overall ministerial exception fails |
| Role of titles, training, and self‑identification in minister status | Biel lacked religious title, training, and did not hold herself out as a minister | St. James points to handbook/contract obligations and expectations that teachers be Catholic educators | Held: Title/training/self‑identification weigh against exception here; not dispositive but important in totality analysis |
| Scope of judicial inquiry if religious justification is offered | Courts may examine motive without resolving religious doctrine | St. James warns courts should defer to religious determinations and avoid entanglement | Held: If exception does not apply, courts may adjudicate ADA claims but must avoid resolving doctrinal questions; district court on remand may consider nondiscriminatory defenses without evaluating religious validity |
Key Cases Cited
- Hosanna‑Tabor Evangelical Lutheran Church & Sch. v. E.E.O.C., 565 U.S. 171 (2012) (establishes ministerial exception and totality‑of‑circumstances factors)
- Puri v. Khalsa, 844 F.3d 1152 (9th Cir. 2017) (applies Hosanna‑Tabor and emphasizes totality test for ministerial exception)
- Grussgott v. Milwaukee Jewish Day Sch., Inc., 882 F.3d 655 (7th Cir. 2018) (applies exception to a religion‑teaching school employee with significant religious duties)
- Conlon v. InterVarsity Christian Fellowship, 777 F.3d 829 (6th Cir. 2015) (applies ministerial exception where employee performed core religious functions)
- Fratello v. Archdiocese of New York, 863 F.3d 190 (2d Cir. 2017) (applies exception to a principal with supervisory liturgical and religious responsibilities)
- N.L.R.B. v. Catholic Bishop of Chicago, 440 U.S. 490 (1979) (limits governmental inquiry into religious organizations to avoid entanglement)
- Bollard v. California Province of the Society of Jesus, 196 F.3d 940 (9th Cir. 1999) (discusses ministerial exception and First Amendment limits on applying employment statutes)