St. Augustine School v. Janet Cropper
2016 SC 000243
| Ky. | Nov 29, 2017Background
- Janet Cropper was the lay administrator (principal) of Saint Augustine School, employed by the Roman Catholic Diocese of Covington for 2011–12 and had her contract renewed for 2012–13.
- On the eve of the 2012–13 school year, Pastor Father Gregory Bach informed Cropper her position was eliminated and her employment terminated, allegedly due to declining enrollment and funding.
- Cropper sued the Diocese, the school, and the pastor asserting multiple claims, including breach of her employment contract; both parties moved for summary judgment.
- The trial court ruled ecclesiastical-abstention did not bar Cropper’s claims but granted summary judgment to Saint Augustine on the ground Cropper could not prove breach of contract.
- The Court of Appeals reversed the grant of summary judgment to the school, holding Cropper could pursue her breach-of-contract claim and rejecting the ministerial-exception defense (not asserted by appellants below).
- The Kentucky Supreme Court granted discretionary review and affirmed the Court of Appeals: ecclesiastical-abstention does not bar Cropper’s breach-of-contract claim and the case is remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ecclesiastical-abstention doctrine bars Cropper’s breach-of-contract claim | Cropper: claim is a secular contract dispute about termination for economic reasons and can be decided by neutral principles | Saint Augustine: dispute involves a church institution and could implicate religious governance, so ecclesiastical-abstention bars adjudication | Court held abstention does not apply because deciding the contract claim requires no interpretation of doctrine; neutral principles suffice |
| Whether the ministerial-exception doctrine applies | Cropper: not raised; she proceeded on ordinary employment-contract theory | Saint Augustine: expressly declined to press ministerial-exception in this case | Court did not analyze ministerial exception because appellants did not pursue it; outcome affirmed on abstention grounds |
Key Cases Cited
- Kirby v. Lexington Theological Seminary, 426 S.W.3d 597 (Ky. 2014) (ecclesiastical-abstention inapplicable where breach-of-contract claim can be resolved by neutral principles)
- Saint Joseph Catholic Orphan Society v. Edwards, 449 S.W.3d 727 (Ky. 2014) (explaining scope of ecclesiastical-abstention and protection for religious organizations)
- Caniff v. CSX Transp., Inc., 438 S.W.3d 368 (Ky. 2014) (standard of review for summary judgment)
- Pearson ex rel. Trent v. Nat'l Feeding Sys., Inc., 90 S.W.3d 46 (Ky. 2002) (summary-judgment standard/principles)