Stanislaw Sterlinski v. Catholic Bishop of Chicago, 934 F.3d 568

Plaintiff Stanislaw Sterlinski was hired as Director of Music at Saint Stanislaus Parish in 1992; demoted to organist in 2014 and fired in 2015.
As Director of Music he selected music, taught choirs, participated in budgeting, and served on an Archdiocese music committee; as organist he played music selected by the priest.
Sterlinski sued the Bishop of Chicago under Title VII alleging discrimination based on Polish heritage.
The key legal question is whether Sterlinski’s organist role is covered by the ministerial exception from Title VII established in Hosanna-Tabor.
The district court granted summary judgment for the Bishop, concluding organist duties are part of religious exercise and thus fall within Hosanna-Tabor; the Seventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an organist is covered by the ministerial exception	Sterlinski: organist role is mechanical—just "plays the notes"—so not ministerial	Bishop: music (including organ playing) is integral to Catholic worship; organist performs religious function	Court: organist role serves religious function; ministerial exception applies
Whether the court may independently adjudicate who counts as a minister	Sterlinski: courts can assess similarity to canonical ministers (as in Biel)	Bishop: courts should defer to church's characterization to avoid entanglement; apply pretext framework	Court: apply pretext approach—if church’s justification is honest and not pretextual, defer; here justification was honest and long-standing

Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC, 565 U.S. 171 (2012) (established ministerial exception to Title VII)
St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (1993) (framework for allocation of burdens and pretext in employment discrimination cases)
Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000) (pretext and burden-shifting principles in employment claims)
Tony & Susan Alamo Foundation v. Secretary of Labor, 471 U.S. 290 (1985) (courts reject overly broad claims that all employees are ministers)
Watson v. Jones, 80 U.S. 679 (1872) (deference to religious organizations on internal matters)
Kedroff v. St. Nicholas Cathedral, 344 U.S. 94 (1952) (First Amendment limits on government interference in church governance)
Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976) (judicial noninterference in ecclesiastical disputes)
Grussgog v. Milwaukee Jewish Day School, Inc., 882 F.3d 655 (7th Cir. 2018) (Seventh Circuit’s multi-factor approach to ministerial-question analysis)
Biel v. St. James School, 911 F.3d 603 (9th Cir. 2018) (Ninth Circuit panel independently assessed ministerial status)
Fratello v. Archdiocese of New York, 863 F.3d 190 (2d Cir. 2017) (declining independent judicial resolution of some ministerial issues)
Cannata v. Catholic Diocese of Austin, 700 F.3d 169 (5th Cir. 2012) (similar deference to religious organization on ministerial matters)