Winbery v. Louisiana College
124 So. 3d 1212
La. Ct. App.2013Background
- Plaintiffs appeal the trial court’s dismissal of their claims under a declinatory exception of lack of subject matter jurisdiction based on the Establishment Clause.
- Defendants urged the ministerial exception under the Free Exercise Clause to bar the suit because the employment relationship involved a religious institution and its ministers.
- The parties previously litigated related defamation and breach claims in 1996, which settled.
- Plaintiffs filed a December 2005 suit alleging defamation, retaliation, academic-freedom violations, and contract breach at Louisiana College; Defendants argued the ministerial exception applied.
- The trial court held it could not resolve the claims without entangling in religious doctrine and dismissed the suit; Defendants’ cross-appeal challenged the ministerial-exception ruling; this Court affirms.
- Louisiana College is not a church, Plaintiffs are not ministers, and resolving the claims would entail improper entanglement with religious doctrine; the ministerial exception is inapplicable and Establishment Clause concerns bar jurisdiction are upheld.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Establishment Clause jurisdiction preclusion? | Plaintiffs argue court can decide neutrally without entanglement. | Defendants contend court would entangle in religious disputes if it decides the claims. | Affirmed; Establishment Clause precludes jurisdiction. |
| Ministerial exception applicability | Plaintiffs contend LC is not a church and plaintiffs are not ministers, so exception does not apply. | Defendants rely on Hosanna-Tabor to show LC is a church and plaintiffs are ministers. | Affirmed; ministerial exception does not apply because LC is not a church and plaintiffs are not ministers. |
Key Cases Cited
- Hosanna-Tabor Evangelical Lutheran Church & School v. Equal Employment Opportunity Comm., 132 S. Ct. 694 (2012) (recognized ministerial exception but limited to employment-discrimination context; no broad bar to other suits)
- Mississippi College v. Baptist Convention, 626 F.2d 477 (5th Cir. 1980) (college not a church; faculty not ministers; ministerial exception not applicable)
- McClure v. Salvation Army, 460 F.2d 553 (5th Cir.) (early articulation of ministerial-exception reasoning)
- LeBlanc v. Davis, 432 So.2d 239 (La. 1983) (bans judicial interference in ecclesiastical matters under Establishment Clause)
- Ambush v. Mount Zion Baptist Church, Inc., 88 So.3d 1077 (La.App.3 Cir. 2012) (La. appellate decision referencing entanglement concerns)