Our Lady of Guadalupe School v. Morrissey-Berru, 140 S. Ct. 2049

Background

Two lay elementary-school teachers (Agnes Morrissey‑Berru at Our Lady of Guadalupe; Kristen Biel at St. James) taught all subjects including daily religion lessons, led or joined daily prayers, prepared students for Mass and sacraments, and were evaluated on religious criteria under employment agreements and faculty handbooks.
Morrissey‑Berru sued after nonrenewal alleging age discrimination (ADEA); Biel sued after nonrenewal alleging disability discrimination tied to cancer treatment leave (ADA/related claims). Both schools invoked the First Amendment "ministerial exception."
District courts granted summary judgment for the schools under the ministerial exception; the Ninth Circuit reversed, emphasizing lack of ministerial title, limited formal religious training, and the teachers’ primarily secular duties.
The Supreme Court granted certiorari and consolidated the cases to decide whether the ministerial exception bars adjudication of these employment‑discrimination claims.
The Court held that the First Amendment forecloses these suits: the ministerial exception applies to these teachers because their core duties were to educate and form students in the Catholic faith; Hosanna‑Tabor’s factors are guides, not a rigid checklist.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the ministerial exception bar employment‑discrimination suits by these teachers?	Morrissey‑Berru/Biel: not ministers — primarily secular duties, lacked ministerial title/commissioning and substantial religious training.	Schools: teachers performed core religious functions (daily religion instruction, prayer, Mass preparation) and contracts/handbooks made the roles religiously central.	Held: Yes; exception bars the claims—focus on function and religious mission, not formal title alone.
What test determines who qualifies as a “minister” under Hosanna‑Tabor?	Plaintiffs: require title/training/public representation; otherwise exception should not apply.	Schools: courts should look at totality and the employee’s role in carrying out the institution’s religious mission.	Held: Hosanna‑Tabor’s factors are non‑exhaustive guides; courts must assess the employee’s function in conveying faith — no rigid checklist.
How much weight may a religious institution’s own description of an employee’s role receive?	Plaintiffs: employer self‑designation cannot be dispositive; courts must independently evaluate.	Schools: the institution’s explanation of roles is important given judges’ limited ecclesiastical competence.	Held: An institution’s explanation is important and courts should give it significant weight while avoiding entanglement in doctrinal matters.
Standard at summary judgment — were genuine disputes of material fact present?	Plaintiffs: factual disputes (titles, training, scope of duties, religious practice) preclude summary judgment.	Schools: record contains abundant evidence of religious functions; no genuine material dispute on applicability of exception.	Held: No material dispute preventing application of the exception here; Ninth Circuit erred to treat Hosanna‑Tabor factors as a rigid checklist and to deny summary judgment.

Key Cases Cited

Hosanna‑Tabor Evangelical Lutheran Church and School v. EEOC, 565 U.S. 171 (2012) (recognized the ministerial exception and identified non‑rigid factors to assess who qualifies as a minister)
Kedroff v. Saint Nicholas Cathedral of Russian Orthodox Church in N. Am., 344 U.S. 94 (1952) (protects religious institutions’ autonomy in matters of faith and church governance)
Watson v. Jones, 13 Wall. 679 (U.S. 1872) (early precedent on civil courts deferring in internal church disputes)
Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976) (defers to internal religious governance and rejects civil intrusion into doctrinal disputes)
Presbyterian Church in U.S. v. Mary Elizabeth Blue Hull Mem’l Presbyterian Church, 393 U.S. 440 (1969) (civil courts must not resolve controversies over religious doctrine)
McClure v. Salvation Army, 460 F.2d 553 (5th Cir. 1972) (early application of what became the ministerial exception)