Monday, April 5, 2021

St. James Catholic School v. Biel

St. James Catholic School was founded in 1918 with the goals of combining academic excellence with religious influence and teachings. Ms. Biel was a fifth grade teacher, the only one at the time at this school, at St. James and held various responsibilities that exceeded that of a normal teacher. She was responsible for teaching religion classes on Catholicism each week, leading students in prayer, bringing the students to Mass, and creating a curriculum that infuses the Catholic faith within it. However, Ms. Biel’s classes performance fell below the school’s standards and after giving her some months to improve, which it did not, they decided to not renew her contract and let her go. After her firing, Ms. Biel made the decision to sue St. James school but lost her case in the district courts. From her she appealed her case and won in the circuit courts due to the court’s reasoning that St. James does not hold the rights as a church when it comes to choosing who teachers their faith. This led to Becket, a non-profit public interest law firm that looks to protect the freedom of religion of all people, filing a petition for review of this case to the Supreme Court. 

In this case, the district court’s ruling may be a potential violation of one of the clauses of St. James’ First Amendment rights. The Free Exercise Clause protects citizens' right to practice their religion as they please, so long as the practice does not run afoul of a public morals or a compelling governmental interest. Here, one must ask the question if St. James retains the right to fire their religious personnel with the same freedom as a church. To look at this case correctly, one must first understand the stipulations for this free exercise that was granted by the case Hosanna-TaborEvangelical Lutheran School v. EEOC. In this case, the question of, “can the government force a church to retain a minister who violates church teachings?”, was answered. The Lutheran Church and School had fired one Cheryl Perich, a commissioned minister and teacher, for insubordination and disorderly conduct, all violations of church teachings. Perich decided to sue and the church argued that forcing them to keep Perich on their staff against their will was an unconstitutional restriction on their rights to choose their own leader. This concept comes from what was mentioned before as a Ministerial Exception. Ministerial Exception prohibits legal claims against church bodies by their employees who carry out religious duties. This is to prevent the government from interfering with church practices and inadvertently choosing a church’s religious leaders. Within this case, Perich argued that the ministerial exception should not apply and that religious personnel should retain the right to sue those who employ them. However, it was thus stated that this was a constitutionally protected right and prevents excessive entanglement between church and state. Furthermore, the court expanded on the broad term of what is considered a “minister”. It was stated by Justice Samuel Alito that a minister is, “any employee who leads a religious organization, conducts worship services or important religious ceremonies or rituals, or serves as a messenger or teacher of its faith.” The Supreme Court then ruled unanimously for Hosanna-Tabor with the belief that religious groups should be free from government interference when they choose their leaders.   


The Supreme Court ruled in favor of St James Catholic School and stated that the government cannot control the school's decision about who teaches its religion classes. I agree with the court’s holding on this case. A minister holds a position in which their job is deeply involved with passing on the teachings of their faith. The government should not be able to decide who the religious leaders are of the church because that can lead to the government essentially running the church by keeping leaders within the church that fit the government’s agendas. This slippery slope can lead to an establishment violation as this could enact state sponsored religious leaders within the church which would be an establishment of a state religion basically. Furthermore, I agree with the court’s broadening of the term “minister” within the case Hosanna-Tabor Evangelical School v. EEOC. This protects the parish schools from being forced to retain employees who aren’t ordained fully but still pass on the teachings of the faith. Thus protecting religious institutions rights to dictate who educates others on their religion. If a teacher holds responsibilities of teaching the faith in any capacity, then they should fall under the umbrella term of a minister within this context.

1 comment:

  1. I think in addition to the fact that she performed religious duties the school should have full freedom to fire a teacher if they feel as though they are not fulfilling their duties or responsibilities to the extent that they should be. Suing a past employer because you were fired with cause is kind of poor practice regardless of your duties and they type of job you were in.

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