Schmidt v. University of Northwestern-St Paul, 0:23-cv-02199

Rolanda Schmidt, a former Assistant Professor of Business and Program Manager at the University of Northwestern-St. Paul (a private Christian university), sued the University for employment discrimination and retaliation based on race and gender under Title VII and negligent supervision under state law.
Schmidt alleges she experienced workplace discrimination, harassment (including hate crimes), and retaliation, claiming the University failed to address these issues before ultimately terminating her employment.
All faculty at the University, regardless of discipline, are expected to integrate Christianity into teaching and are viewed as “ministers” tasked with both intellectual and spiritual growth of students.
The University moved for summary judgment, arguing the “ministerial exception” under the First Amendment bars the court from hearing Schmidt’s claims involving employment discrimination against religious institutions by “ministers.”
Discovery was bifurcated to first determine whether the ministerial exception applies before full discovery on other issues; the case is at the summary judgment stage focusing on this threshold question.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is University a religious institution?	University not a religious institution (recently)	University is a religious institution	Yes; school’s Christian mission qualifies it as religious under precedent
Is Schmidt a "minister" for the exception?	Schmidt not a minister, only taught secular classes	Schmidt acted as minister by integrating faith into teaching	Yes; faculty held out as ministers, expected to integrate faith, so exception applies
Does ministerial exception bar Title VII?	Exception should not apply to her Title VII claim	Ministerial exception bars court from hearing Title VII	Yes; exception bars interference in Title VII employment claim
Does ministerial exception bar negligent supervision?	Not fully briefed; claim should proceed	Exception may bar claim if ecclesiastical matters implicated	Unclear; summary judgment denied without prejudice, further briefing/discovery needed

Hosanna-Tabor Evangelical Lutheran Church & Sch. v. E.E.O.C., 565 U.S. 171 (2012) (establishes the ministerial exception to employment discrimination suits against religious institutions)
Our Lady of Guadalupe Sch. v. Morrissey-Berru, 591 U.S. 732 (2020) (further expands ministerial exception to teachers entrusted with educating in the faith)
Starkey v. Roman Cath. Archdiocese of Indianapolis, Inc., 41 F.4th 931 (7th Cir. 2022) (applies ministerial exception to a Catholic high school guidance counselor)
Billard v. Charlotte Cath. High Sch., 101 F.4th 316 (4th Cir. 2024) (applies ministerial exception to an English and drama teacher at a Catholic high school)
Conlon v. InterVarsity Christian Fellowship, 777 F.3d 829 (6th Cir. 2015) (ministerial exception applies to non-denominational Christian organizations)