Reyzl Grace MoChridhe, Appellant, vs. Academy of Holy Angels, Respondent, Archdiocese of St. Paul and Minneapolis, Respondent.
A25-0559
STATE OF MINNESOTA IN COURT OF APPEALS
December 1, 2025
Larkin, Judge
Hennepin County District Court, File No. 27-CV-24-11601
Joni M. Thome, Katherine Rollins, Wanta Thome PLC, Minneapolis, Minnesota (for appellant)
Katie M. Connolly, Sara Gross Methner, Sara L. Lewenstein, Nilan Johnson Lewis PA, Minneapolis, Minnesota; and
Thomas B. Wieser, Thomas Wieser Law, West St. Paul, Minnesota (for respondent Holy Angels)
Paul J. Zech, Scott D. Blake, Felhaber Larson, Minneapolis, Minnesota; and
Lorie S. Gildea, Greenberg Traurig, LLP, Minneapolis, Minnesota (for respondent Archdiocese)
Leslie L. Lienemann, Celeste E. Culberth, Culberth & Lienemann, LLP, St. Paul, Minnesota; and
Brian T. Rochel, Kitzer Rochel, PLLP, Minneapolis, Minnesota; and
Drew Kudlinski, HKM Employment Attorneys, LLP, Minneapolis, Minnesota; and
Stephen M. Premo, Premo Frank PLLC, Minneapolis, Minnesota; and
Zane Umsted, Madia Law LLC, Minneapolis, Minnesota (for amicus curiae Employee Lawyers of the Upper Midwest and Minnesota National Employment Lawyers Association)
Caitlin L. Opperman, Nichols Kaster, PLLP, Minneapolis, Minnesota; and
Teresa Nelson, Alicia Granse, Hannah Grayson, American Civil Liberties Union of Minnesota, Minneapolis, Minnesota (for amicus curiae American Civil Liberties Union of Minnesota)
Celeste E. Culberth, Culberth & Lienemann, LLP, St. Paul, Minnesota (for amicus curiae Americans United for Separation of Church and State)
Considered and decided by Bond, Presiding Judge; Ross, Judge; and Larkin, Judge.
SYLLABUS
A court properly dismisses sex or sexual orientation employment-discrimination claims against a church under
OPINION
LARKIN, Judge
Appellant, a former media specialist/librarian at a Catholic school, challenges the district court‘s dismissal of her employment-discrimination claims against respondent Archdiocese, which were based on sex and sexual orientation. Because appellant‘s
FACTS
In August 2024, appellant Reyzl Grace MoChridhe sued respondents Academy of Holy Angels and Archdiocese of St. Paul and Minneapolis,1 alleging discrimination, specifically, nonrenewal of MoChridhe‘s employment contract based on MoChridhe‘s sex and sexual orientation. Our recitation of the facts is taken from MoChridhe‘s complaint and the documents referenced in her complaint. We accept the factual allegations in her complaint as true and construe all reasonable inferences in her favor. See Bodah v. Lakeville Motor Express, Inc., 663 N.W.2d 550, 553 (Minn. 2003) (“The reviewing court must consider only the facts alleged in the complaint, accepting those facts as true and must construe all reasonable inferences in favor of the nonmoving party.“).
As alleged in her complaint, MoChridhe is Jewish and “a transgender woman, meaning she was assigned male at birth but lives and identifies as a woman.” On July 19, 2021, Holy Angels presented MoChridhe “with an offer of employment and a detailed job description for a Media Specialist/Librarian position to be reviewed and signed.” MoChridhe “signed the Employment Agreement that same day.” According to MoChridhe‘s complaint, the job description contains a “Purpose” section that “describes the mission statement of [Holy Angels]” and states “[t]he mission of [Holy Angels] is to educate and nurture a diverse student population” and “[t]he Media Specialist/Librarian
According to the complaint, “[t]he ‘Bylaws of [Holy Angels]’ state that [Holy Angels‘] Board‘s actions are to be at all times ‘informed by and conducted in accordance with the tenets of the Roman Catholic Church as determined by the Archbishop of the Archdiocese.‘” Holy Angels provided MoChridhe with an employee handbook, which indicated that her benefits would be provided by the Archdiocese.
MoChridhe‘s employment agreement covered the 2021-22 school year. In March 2022, all Holy Angels staff were asked to submit an intention to renew their employment agreement for the 2022-23 school year by April 22, 2022. If they did not do so, their resignations would be assumed. Soon after, MoChridhe met with Holy Angels’ principal. MoChridhe told the principal that she wanted to come back but that she first wanted to confirm there was interest in having her return. The principal assured MoChridhe that the school wanted her to return. MoChridhe then “revealed she had come out as transgender and was starting the process of transitioning to live as her female self.” The principal said the Archdiocese would not support MoChridhe‘s transition, and it would not be possible for MoChridhe to continue working at the school if she was determined to transition.
Guiding Principles for Catholic Schools and Religious Education Concerning Human Sexuality and Sexual Identity
Purpose
The Catholic school is committed to providing a safe environment that allows students to flourish academically, physically, and spiritually. Catholic schools are obliged to provide an education and resources consistent with Catholic teaching. The starting point for Catholic education is a deeply held understanding that affirms the God-given irrevocable dignity of every human person.
Catholic teaching permeates and shapes the ethos of Catholic schools. Informed by Catholic teaching, these Guiding Principles shall inform the creation of policies, handbooks, statements, employee agreements, training for employees, and the approach to accompaniment in the Catholic schools of the Diocese of [insert], thus ensuring that the immeasurable dignity of every child is protected and respected, particularly as it relates to foundational beliefs of the Catholic Church:
- God created each person body and soul “in His own image, in the image of God he created them; male and female he created them” (Gen. 1:27). The dignity of each person and the source of his or her most important identity is found in this creation in the image and likeness of God (CCC §364).
- God uses the body to reveal to each person his or her sexual identity as male or female. A person‘s embrace of his or her God-given sexual identity is an essential
part of living a fulfilled relationship with God, with oneself, and with each other (Laudato Si §155). - The harmonious integration of a person‘s sexual identity with his or her sex is an expression of the inner unity and reality of the human person made body and soul in the image and likeness of God (CCC §364-65).
- The physical, moral, and spiritual differences between men and women are equal and complementary. The flourishing of family life and society depend in part on how this complementarity and equality are lived out (CCC §2333-34).
- All students and families deserve interactions with Catholic school communities that are marked by respect, charity, and the truth about human dignity and God‘s love (Deus Caritas Est §20).
Application of Guiding Principles
The aforementioned Guiding Principles are practically applied in Catholic schools. Catholic schools in the Diocese of [insert] will relate to each student in a way that is respectful of and consistent with each student‘s God-given sexual identity and biological sex. To this end, below are some examples of how these Guiding Principles apply to organizations that teach children and youth in the name of the Catholic Church in the Diocese of [insert].
1. All school policies, procedures, resources, employee training, and assistance given to families will be consistent with the Church‘s teaching on the dignity of the human person, including human sexuality. Reflective of a commitment to a culture of transparency and understanding, these policies will be made available in writing to members of the school community by way of inclusion in relevant handbooks, agreements, and statements.
2. Student‘s name and pronoun usage will correspond to his/her sex (see definitions). 3. Student access to facilities and overnight accommodations will align with his/her sex.
4. Eligibility for single-sex curricular and extracurricular activities will be based on the sex of the child.
5. Expressions of a student‘s sexual identity are prohibited when they cause disruption or confusion regarding the Church‘s teaching on human sexuality.
6. Students who attend and employees who work at a Catholic school can expect that the school acknowledges that God has created each person as a unity of body and soul, as male or female, and that God-designed sexual expression and behavior must be exclusively oriented to love and life in marriage between one man and one woman.
7. Schools will communicate with parents or guardians about their child‘s behavior at school and inform them of any concerns relating to the physical, emotional, social, and spiritual health, safety, or welfare of their child, except when advised otherwise by law enforcement or a social service agency.
Definitions
1. Sex refers to a person‘s biological identification as male or female based upon physical characteristics present at birth.
2. Sexual identity refers to a person‘s identity as male or female that is congruent with one‘s sex.
3. Sexual binary refers to the God-given gift of the human family created male or female in the image and likeness of God.
4. Transgender or gender non-conforming is an adjective describing a person who perceives his or her sexual identity to be different from his or her sex and publicly presents himself or herself as the opposite sex or outside the sexual binary. Such
public expressions that are intended to communicate a sexual identity different from one‘s sex include, but are not limited to, utilizing pronouns of the opposite sex, changing one‘s name to reflect the cultural norms of the opposite sex, wearing a uniform designated for the opposite sex, and undergoing surgery to change the appearance of one‘s reproductive or sexual anatomy.
The principal asked MoChridhe if she could adhere to the Guiding Principles. Holy Angels had not previously shown MoChridhe the Guiding Principles or anything like it. After reviewing the Guiding Principles, MoChridhe said that “she did not believe she could abide by the directives.” MoChridhe‘s complaint alleges that the Guiding Principles “instruct schools who teach in the name of the Catholic Church to discriminate against transgender and gender-nonconforming students by, for example, refusing to recognize their pronouns and preferred name if they are inconsistent with a student‘s sex assigned at birth, and refusing to allow LGBTQ+ students to express their sexual identity.”
According to MoChridhe‘s complaint, the principal told MoChridhe “that the Guiding Principles document was the only reason she was not being offered a renewed contract.” It was clear to MoChridhe that “what she was being told was that she would not be allowed to work at [Holy Angels] given that she is transgender.” The principal asked MoChridhe to submit a formal resignation letter by June 7, 2022. MoChridhe did not do so.
On April 22, 2022, the final day to submit an employee‘s intent to return, MoChridhe contacted Holy Angels’ human resources (HR) department. The HR representative was not aware of MoChridhe‘s previous conversations with the principal. MoChridhe told the HR representative that “she wanted it on record that she wanted to
In June 2022, Holy Angels posted a job opening for the library/media specialist position. MoChridhe‘s complaint states that “[a]s with the previous posting for the position, the posting did not list any ministerial duties and did not require any religious training or education.” MoChridhe applied for the position using the same application that had been used the year prior with updated information including the experience she gained during her year of employment at Holy Angels. MoChridhe did not get a response to the updated application until August 1, 2022, when an HR representative sent her a letter thanking her for the application but indicating the position had been filled. MoChridhe finished out her 2021-22 contract with Holy Angels on August 15, 2022.
MoChridhe filed a discrimination charge with the Minnesota Department of Human Rights (MDHR). MoChridhe submitted her charge on a form, and she checked boxes indicating employment discrimination based on sex and sexual orientation/gender identity in violation of the Minnesota Human Rights Act (MHRA),
MoChridhe‘s ensuing complaint against Holy Angels and the Archdiocese raised three MHRA claims and one common-law claim: (1) discrimination in employment based on sexual orientation (gender identity) under
The Archdiocese moved to dismiss MoChridhe‘s claims against the Archdiocese under
The district court relied on two documents referenced in the complaint and filed by the Archdiocese in support of its motion to dismiss: the Guiding Principles and a copy of the discrimination charge that MoChridhe filed with the MDHR. The district court concluded that MoChridhe‘s claims against the Archdiocese were based on the Guiding Principles, which the Archdiocese imposed on Holy Angels, and that resolution of MoChridhe‘s claims therefore required examination of the Archdiocese‘s faith-based doctrines, the relationship between the Archdiocese and Holy Angels, church governance, and the provision of education through Holy Angels. Again, MoChridhe‘s complaint alleges that Holy Angels’ bylaws state that Holy Angels’ board‘s actions are to be at all times “informed by and conducted in accordance with the tenets of the Roman Catholic Church as determined by the Archbishop of the Archdiocese.” The district court therefore determined that the religious-freedom provisions in the United States and Minnesota Constitutions precluded MoChridhe‘s claims. The district court also determined that MoChridhe‘s MHRA sexual-orientation claim failed under
ISSUE
Did the district court err in dismissing MoChridhe‘s claims against the Archdiocese on the ground that the claims are precluded by the church autonomy doctrine under the First Amendment to the United States Constitution?
ANALYSIS
We review a grant of a motion to dismiss under
Under the MHRA, it is an unfair employment practice for an employer to refuse to hire or to discharge an employee because of the employee‘s sex or sexual orientation.
There is no dispute that MoChridhe sufficiently pleaded her claims for violations of the MHRA. Instead, we are asked to decide whether those MHRA claims, as pleaded, are foreclosed by the First Amendment.
The First Amendment
The First Amendment to the United States Constitution provides that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof.”
The Church Autonomy Doctrine
“The legal principle that has come to be known as the ‘ecclesiastical abstention doctrine’ or the ‘church autonomy doctrine’ has its roots in a line of U.S. Supreme Court decisions regarding church property and church schisms.”3 Pfeil, 877 N.W.2d at 532. Although none of those decisions directly addresses the factual circumstances of this case, “several helpful rules can be drawn from them.” Id. at 534. Among them is the following rule: although courts can resolve disputes involving religious organizations, they may do so “only if” (1) they are “able to resolve the matter by relying exclusively on neutral principles of law,” (2) they do not “disturb the ruling of a governing ecclesiastical body with respect to issues of doctrine,” and (3) “the adjudication does not interfere with an internal church decision that affects the faith and mission of the church itself.” Id. (quotation omitted). The third factor is dispositive here.
We reach a similar conclusion here. We recognize that the allegations in MoChridhe‘s complaint are unlike the facts in Doe in that she is not an ordained minister, she was not a teacher or pastor at the school, and her position was secular. Regardless of the secular nature of the job posting, MoChridhe‘s complaint alleged that “[t]he ‘Bylaws of [Holy Angels]’ state that [Holy Angels‘] Board‘s actions are to be at all times ‘informed by and conducted in accordance with the tenets of the Roman Catholic Church as determined by the Archbishop of the Archdiocese.‘” Thus, consideration of MoChridhe‘s claims—as alleged in her complaint—would require the judiciary to consider the role that church doctrine played in the decision not to renew her employment contract with Holy Angels. Importantly, it would require the judiciary to consider the Archdiocese‘s decision to require an employee in one of its Catholic schools to adhere to its faith-based Guiding Principles in the school setting.
According to MoChridhe‘s complaint, Holy Angels’ principal asked MoChridhe if she “could adhere to the document‘s requirements.” “After reviewing the Guiding Principles,” MoChridhe said “she did not believe she could abide by the directives.” As to the directives, MoChridhe‘s complaint alleges that the Guiding Principles document “instruct[s] schools who teach in the name of the Catholic Church to discriminate against transgender and gender-nonconforming students by, for example refusing to recognize their pronouns and preferred name if they are inconsistent with a student‘s sex assigned at birth, and refusing to allow LGBTQ+ student to express their sexual identity.” In sum,
MoChridhe argues that adjudication of her claims will not require the judiciary to interpret church doctrine. She may be correct, but that does not end our inquiry under the church autonomy doctrine. The Archdiocese‘s decision to require an employee in one of its Catholic schools to adhere to its faith-based Guiding Principles in the school setting “affects the faith and mission of the church itself.” Pfeil, 877 N.W.2d at 534 (quotation omitted). As to this issue, courts have recognized that “[t]he education of children within a Catholic school system is a significant factor in the propagation of the Catholic faith.” Hill-Murray Fed‘n of Tchrs. v. Hill-Murray High Sch., 487 N.W.2d 857, 865 (Minn. 1992). “[E]ducating young people in their faith, inculcating its teachings, and training them to live their faith are responsibilities that lie at the very core of the mission of a private religious school.” Our Lady of Guadalupe, 591 U.S. at 753-54. In short, “[i]n the Catholic tradition, religious education is intimately bound up with the whole of the Church‘s life.” Id. at 754 (quotations omitted).
Consistent with the mission of a private religious school, and as acknowledged in MoChridhe‘s complaint, “[t]he mission of [Holy Angels] is to educate and nurture a diverse student population,” and the media specialist/librarian “collaborates with the professional staff to support the mission of the Academy of Holy Angels.” Although MoChridhe acknowledges—in her complaint—that as the media/specialist, she was expected to “collaborate[] with the professional staff to support the mission of the Academy of Holy
In short, MoChridhe asks the judiciary to require the Archdiocese to employ a person who does not support and will not abide by the church‘s faith-based Guiding Principles in the school setting, despite the Archdiocese‘s internal decision to require adherence to those principles when executing its mission to educate students in the Catholic faith. MoChridhe does not cite, and we are not aware of, any case that compels that result in the face of a church‘s religious protections under the First Amendment. Again, training young people to live their faith “lie[s] at the very core of the mission of a private religious school.” Our Lady of Guadalupe, 591 U.S. at 753-54. Given the significant role that the Catholic faith plays in Catholic education and the church‘s mission to train young people to live the Catholic faith, requiring the Archdiocese to employ a person in its Catholic school who admittedly cannot abide by the church‘s implementation of its Guiding Principles in that school would interfere with an internal church decision that affects the faith and mission of the church itself. Cf. Hill-Murray, 487 N.W.2d at 866 (stating that under the Minnesota Constitution, although a Catholic high school could be subject to the Minnesota Labor Relations Act, the school retained “the power to hire employees who meet their religious expectations, to require compliance with religious doctrine, and to remove any person who fails to follow [its] religious standards“).
The principle that a claim against a church is foreclosed if a court‘s adjudication of the claim would interfere with an internal church decision that affects the faith and mission of the church itself is substantially similar to a related principle: a state action must not
- That the practices of Defendants complained of herein be adjudged, decreed, and declared to be in violation of the rights secured to Plaintiff by the . . . [MHRA].
- That a permanent injunction be issued prohibiting Defendants from engaging in the practices complained of herein.
- That the Court order Defendants to pay a civil penalty to the State of Minnesota pursuant to
Minn. Stat. § 363A.29 . - That Plaintiff be awarded compensatory damages in an amount greater than $50,000.
- That Plaintiff be awarded treble damages pursuant to
Minn. Stat. §§ 363A.33 and363A.29 . - That Plaintiff be awarded punitive damages pursuant to
Minn. Stat. § 363A.29 in an amount to be determined at trial. - That the Court issue an order enjoining Defendants and their officers, agents, and employees from subjecting Plaintiff to differential treatment and from any retaliation against Plaintiff for prior actions, or for bringing this action.
- That the Court retain jurisdiction until the Court is satisfied that the Defendants have remedied the practices complained of herein and are determined to be in full compliance with the law.
(Emphasis added.)
In sum, MoChridhe asks the Minnesota judiciary to issue a secular judgment decreeing the Archdiocese‘s implementation of Catholic doctrine in Catholic schools illegal, to monitor the Archdiocese until the Minnesota judiciary is “satisfied” that the Archdiocese has abandoned the allegedly illegal implementation of its religious doctrine in its Catholic schools, and to financially sanction the Archdiocese for adhering to its faith-
The government may not compel a church to conform its sincerely held religious beliefs to those of the government. See Geraci v. Eckankar, 526 N.W.2d 391, 399 (Minn. App. 1995) (“If courts begin to question a church‘s basis for doctrinal decisions, a church may be compelled to conform its religious beliefs with the government‘s or the majority culture‘s beliefs.“), rev. denied (Minn. Mar. 14, 1995). “[A]ny attempt by government to dictate or even to influence [matters of faith and doctrine] would constitute one of the central attributes of an establishment of religion,” which “the First Amendment outlaws.” Our Lady of Guadalupe, 591 U.S. at 746. MoChridhe seeks to do exactly that. The First Amendment does not allow it.
MoChridhe‘s Arguments
MoChridhe makes five arguments in support of her contention that her lawsuit does not violate the First Amendment and should not have been dismissed. None is persuasive.
MoChridhe argues that the church autonomy doctrine does not foreclose her lawsuit for the following reasons: (1) she “is a lay employee who brought colorable claims of discrimination and negligence under neutral and generally applicable laws,” (2) she “was neither qualified nor expected to minister the Catholic faith or to be a member of the Catholic church,” and (3) she does not challenge the Archdiocese‘s “interpretation of scripture and does not raise a dispute over church property, church membership or excommunication, nor does she ask a court to resolve any such dispute.”
Although MoChridhe has identified some factual differences between this case and precedent, we are not persuaded that those differences require a conclusion that judicial resolution of MoChridhe‘s claims would not unconstitutionally intrude on the autonomy of the Catholic Church or entangle the church and state in way that is constitutionally intolerable. The factual differences merely present a need to apply precedent to a set of facts not previously considered. Under the facts and circumstances of this case, application of precedent supports a conclusion that MoChridhe‘s claims cannot be adjudicated by the judiciary without violating the religious freedom provisions of the First Amendment.
2.
MoChridhe argues that she asks the judiciary to determine only whether the MHRA “prohibits a religious institution from firing a transgender person,” and “not whether a religious institution, like [the Archdiocese], has properly interpreted its religious doctrine
MoChridhe‘s complaint alleges that the Guiding Principles were “the only reason” for the employment decision that is at issue here. The Guiding Principles state that they are “practically applied in Catholic schools.” And binding precedent recognizes the significant role that Catholic faith plays in the Catholic school setting. Adjudicating MoChridhe‘s claims would require the judiciary to interfere with an internal church decision related to the church‘s mission to train its Catholic school students to live according to the Catholic faith. We cannot ignore the First Amendment implications of MoChridhe‘s lawsuit.
3.
MoChridhe argues that the federal constitution does not prohibit application of neutral, generally applicable regulatory laws to religious litigants. She relies on
But the Supreme Court limited application of Smith in Hosanna-Tabor, explaining:
It is true that the [Americans with Disabilities Act‘s] prohibition on retaliation, like Oregon‘s prohibition on peyote use, is a valid and neutral law of general applicability. But a church‘s selection of its ministers is unlike an individual‘s ingestion of peyote. Smith involved government regulation of only outward physical acts. The present case, in contrast, concerns government interference with an internal church decision that affects the faith and mission of the church itself.
565 U.S. at 190. While we are mindful of the distinction between a religious minister and a secular media specialist/librarian, we conclude that this case is like Hosanna-Tabor, and not like Smith. This case concerns government interference with an internal church decision that affects the faith and mission of the church itself, and not a criminal act. Smith is further distinguishable because it did not involve a religious employer and did not raise the same concerns that are at issue here. See Smith, 494 U.S. at 874.
MoChridhe argues that this case cannot be resolved with a dismissal under
5.
Finally, MoChridhe argues regarding the relevance of the “ministerial exception” in this case. Under that exception, churches and religious organizations are categorically exempt from compliance with employment-discrimination statutes when making decisions regarding ministerial employees. Hosanna-Tabor, 565 U.S. at 185-89.
MoChridhe argues that even though the Archdiocese did not raise the ministerial exception in district court, “it is difficult to discuss the interaction between anti-
The Archdiocese did not request dismissal under the ministerial exception in the district court, and the district court did not consider application of that exception when dismissing MoChridhe‘s claims. “A reviewing court must generally consider only those issues that the record shows were presented [to] and considered by the trial court in deciding the matter before it.” Thiele v. Stich, 425 N.W.2d 580, 582 (Minn. 1988) (quotation omitted). However, that is not “an ironclad rule.” Oanes v. Allstate Ins. Co., 617 N.W.2d 401, 403 (Minn. 2000). Because there are no factual disputes that affect the purely legal question of whether First Amendment protections are available in this case only under the ministerial exception, we will briefly address the issue. See
The Supreme Court has not expressly addressed this issue. Its seminal cases are Hosannah-Tarbor and Our Lady of Guadalupe. In Hosanna-Tabor, the Supreme Court
Although the Hosanna-Tabor Court determined that the exception applied in that case, noting that the case concerned “government interference with an internal church decision that affects the faith and mission of the church itself,” the Court did not address whether the religious protections of the First Amendment are available to a religious employer defending an employment-discrimination claim by a non-minister who was terminated for religious reasons. Id. at 190.
In Our Lady of Guadalupe, the Supreme Court extended the reach of the ministerial exception, stating that “whether a particular position falls within the . . . exception, a variety of factors may be important.” 591 U.S. at 751. “What matters, at bottom, is what an employee does.” Id. at 753. Again, the Court did not address whether the religious protections of the First Amendment are available to a religious employer defending an employment-discrimination claim by a non-minister who was terminated for religious reasons.
So long as the employer determines that an employee‘s duties are vital to carrying out the mission of the church, then today‘s laissez-faire analysis appears to allow that employer to make employment decisions because of a person‘s skin color, age, disability, sex, or any other protected trait for reasons having nothing to do with religion.
Id. at 784 (Sotomayor J., dissenting) (emphasis added) (quotations and citation omitted). Finally, the dissent asserted that the majority‘s decision “permit[ed] religious entities to discriminate widely and with impunity for reasons wholly divorced from religious beliefs.” Id. at 784-85 (Sotomayor J., dissenting) (emphasis added).
The dissent‘s emphasis on a church‘s ability to obtain First Amendment protection from a discrimination claim by a terminated employee based only on a determination that
As this case shows—on the face of MoChridhe‘s complaint—the decision not to offer her renewed employment at Holy Angels was based only on a religious reason: her stated inability to abide by the directives in the Guiding Principles, as applied in the school setting. Thus, consideration of MoChridhe‘s claims would require consideration of the Archdiocese‘s religious reason for the employment decision, would interfere with the Archdiocese‘s internal decision to require compliance with the Guiding Principles in the school setting—which relates to the church‘s mission to educate young people in its faith—and would foster excessive governmental entanglement with religion. The potential
In conclusion, we recognize the apparent tension between the government‘s interest in eliminating discrimination and the religious freedoms protected by the First Amendment. “The interest of society in the enforcement of employment discrimination statutes is undoubtedly important. But so too is the interest of religious groups in choosing who will preach their beliefs, teach their faith, and carry out their mission.” Hosanna-Tabor, 565 U.S. at 196 (emphasis added); see Geraci, 526 N.W.2d at 399 (“There is a tension between eradicating discrimination and permitting the free exercise of religion; however, in this case, the balance weighs in favor of the First Amendment.“).
Based on our application of precedent to the particular facts of this case—as alleged in MoChridhe‘s complaint—we hold that because the allegations in MoChridhe‘s complaint, construed in her favor, establish that the district court‘s adjudication of her claims would violate the religious protections of the First Amendment as a matter of law, the district court properly dismissed MoChridhe‘s employment discrimination claims against the Archdiocese for failure to state a claim under
DECISION
Because the allegations in MoChridhe‘s complaint would interfere with an internal church decision that affects the Archdiocese‘s faith-based mission to educate young people in the Catholic faith and would foster excessive governmental entanglement with religion,
Affirmed.