Prince of Peace Lutheran Church v. Linklater
28 A.3d 1171
Md.2011Background
- Respondent Mary Linklater was the music director at Prince of Peace Lutheran Church in Montgomery County, Maryland.
- She filed a complaint on October 16, 2002 asserting sixteen claims including sexual harassment, hostile work environment, discrimination, retaliation, and related torts against the Church, Pastor Lusk, the Synod, and related entities.
- The Circuit Court granted summary judgment on several counts and a new trial on the IIED count; it also admitted a joint financial statement; the jury awarded mixed damages on IIED and related claims.
- The Court of Special Appeals held that the IIED claim failed as a matter of law, that Counts I and III were saved by the continuing violation doctrine, and that Counts I and III could be pursued only against certain defendants.
- The Maryland Court of Appeals granted certiorari to address (1) the ministerial exception's scope and its application to the 16 counts, and (2) whether the continuing violation doctrine applies to the 49B county code claims and related timeliness issues.
- The Court ultimately held that the ministerial exception does not bar Counts I and III, that Counts II is barred, and that Counts IV, V, X, XIV, and XV are barred by the ministerial exception, with remand instructions regarding Counts I and III.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of ministerial exception. | Linklater argues broader protection for church governance. | Church contends ministerial exception covers governance and related decisions. | Ministerial exception does not bar I and III but does bar II; it is not as broad as to bar retaliation claims if not doctrinal. |
| Whether Counts I and III are timely due to continuing violation. | Counts I and III saved by continuing violation. | Actions after limitations period barred unless saved by ministerial exception. | Continuing violation doctrine applies to Counts I and III for timely components within the period. |
| Whether Counts II, IV, V, X, XIV, XV are barred by ministerial exception. | Some claims do not rely on church governance background. | These claims involve church governance or ministerial decisions. | Counts II, IV, V, X, XIV, XV barred by ministerial exception; Counts I and III survive as to those defendants. |
| Effect of Lusk speech to congregation on limitations. | Speech could rescue timely claims under continuing violation. | Speech is protected by ministerial exception when related to church governance. | Speech not wholly protected; continuing violation evidence (photograph incident) supports timely claims. |
| Remand and allocation of costs on remaining counts. | Reinstate jury verdict and remand for further proceedings. | Affirm judgments in favor where appropriate. | CSA remanded Counts I and III to proceed against Lusk/Church; other counts affirmed or remanded as directed. |
Key Cases Cited
- Sanders v. Casa View Baptist Church, 134 F.3d 331 (5th Cir. 1998) (minority of ministerial insulation limited to doctrinal matters)
- Bollard v. California Province of the Society of Jesus, 196 F.3d 940 (9th Cir. 1999) (limits ministerial exception to religiously motivated employment decisions)
- McKelvey v. Pierce, 173 N.J. 26, 800 A.2d 840 (2002) (warns against broad ministerial exemption in religious disputes)
- Black v. Snyder, 471 N.W.2d 715 (Minn. Ct. App. 1991) (harassment claim allowed where not rooted in pastoral qualifications)
- Richards v. CH2M Hill, Inc., 111 Cal. Rptr. 2d 87, 29 P.3d 175 (Cal. 2001) (course-of-conduct continuing-violation approach adopted; relates to hostility over time)
- EEOC v. Catholic Univ. of Am., 83 F.3d 455 (D.C. Cir. 1996) (ministerial exception applies to certain religious employment decisions)
- National Railroad Passenger Corp. v. Morgan, 536 U.S. 101 (Supreme Court 2002) (discrete acts outside limitations barred; entire hostile environment claims allowed within period)