In 2017, Joshua Payne-Elliott, a teacher at Cathedral Catholic High School in Indianapolis violated his agreement with the school and the Catholic Church and entered into a same-sex marriage. In the Archdiocese of Indianapolis, all Catholic school educators sign an agreement when they get hired stating that they will uphold the Catholic Church’s teachings not only in their professional lives, but in their personal lives as well. When Mr. Payne-Elliott entered a same-sex marriage in 2017, he tried to work out an agreement with Cathedral Catholic High School, since same-sex marriage is prohibited and looked down upon in the Catholic faith. In addition to this, it also violated his employment agreement with Cathedral Catholic High School. The Archdiocese of Indianapolis and Cathedral Catholic High School spent two years discussing and deliberating about the best plan of action to take regarding Payne-Elliott’s future with the school. Eventually the Archdiocese of Indianapolis gave Cathedral Catholic High School an ultimatum saying that if the school wanted to remain affiliated with the Catholic Church, then they would have to fire Payne-Elliott. Since they wanted to remain a part of the Catholic Church, Cathedral Catholic High School ultimately decided to part ways with Payne-Elliott since he went against the teachings of the Catholic Church. As a result of this Payne-Elliott sued the Archdiocese of Indianapolis claiming that the Archdiocese unjustly and illegally interfered in his agreement process that he was working on with the school.
In May of 2021, the Marion Superior Court of Indiana ruled in favor of the Archdiocese of Indianapolis, however, the Indiana Court of Appeals reversed this decision, ultimately allowing the lawsuit to advance. After this case was reversed, it was brought to the Indiana State Supreme Court. Here the court made a decision that maintained the same ruling made by the Marion Superior Court of Indiana and ruled in favor of the Archdiocese of Indianapolis. The court ruled that the Archdiocese had the right to maintain what they deemed as Catholic values within a private Catholic school, and that religious institutions have the right to decide matters of church government without state interference.
The main constitutional issue in this case is whether or not the Archdiocese of Indianapolis is allowed to step in in this situation and whether these actions violated the separation between church and state. Even though Payne-Elliott was trying to work with the school to come to an agreement, the court decided that the Archdiocese has a right to step in and intervene in this matter because it is a private school and not a public school. It was ruled that the Archdiocese also had a right to do this because of "ministerial exception" which was first used in Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC. The “ministerial exception,” is an exception that gives religious institutions specific rights to control employment matters without interference from the courts.
I agree with the decision of the majority in this case. Constitutionally speaking, a private school has the right to do what they want in regards to maintaining their religious beliefs and views, and the Archdiocese has the right to step in an attempt to make sure that Catholic views and values are properly being transmitted. In Indianapolis, the purpose of these private Catholic schools is to spread the Catholic faith and beliefs to the next generation. Under the Catholic religion, same-sex marriage of any kind is strictly prohibited and looked down upon. As a result, the Catholic Church and Archdiocese believes that having a teacher in a same-sex marriage, does not properly convey and transmit the Catholic faith to future generation like these schools are intended to. In addition to this, when Payne-Elliott got hired at Cathedral Catholic High School, he had to sign a contract stating that he would properly uphold and transfer the beliefs and ideals of the Catholic Church in his professional and personal life. If Payne-Elliott wants to still teach, he could instead apply for jobs at public schools where he cannot be reprimanded or discriminated against due to his sexual orientation. When looking at previous cases such as Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC and Our Lady of Guadalupe School v. Morrissey-Berru which both examined the idea of whether the teachers were “ministers,” we see that Payne-Elliott would not fall under this category. Payne-Elliott would not have the exemption of being a minister because even though he teaches at a Catholic school, he doesn’t teach religion and unlike the other teachers who were discriminated against due to their age and a sickness, Payne-Elliot was fired due to his sexual orientation which directly goes against the teachings of the Catholic Church. If this case were to have taken place under the same circumstances but in a public school, then the outcome of this case would have been completely different, but since it took place while teaching at a private school, the school and the Archdiocese have a right to part ways with him since he is in violation of the agreement made when he started teaching. This issue is important because it shows us how much different circumstances are in a private and religious institution as compared to a public institution. Some people might believe that there is not a big difference between private and public, but this case does a great job of showing how much more restrictive private institutions can be when compared to public institutions.
7 comments:
Insightful post Mike! Although I do agree that private schools have the right to employ and fire whoever they choose, I am curious as to the teachings the school made this decision on, as the highest voice of the Catholic Church, Pope Francis, has come out and said that same-sex individuals are "children of God and have a right to a family. Nobody should be thrown out, or be made miserable because of it [their sexuality]." This statement was years before the decision of the court. However, if the school is interpreting the Catholic religion to be anti-LGBTQ+ then I agree that, Constitutionally, the school is in the right in this sense and the distinction between private and public school makes all the difference in this decision. If this had been a public institution the decision would have most likely looked a lot different.
Alexander, this is a great post. I fully agree with you. However, this is against public morality. That does not matter here. Coming from an all-boys catholic school myself, they were very strict about rules such as these. Anything that violated the teachings of the church would have you asked to leave. As a private institution, they are allowed to hire and fire who they want based on their beliefs. The staff member knew his marriage could be an issue in the eyes of the church and decided to work there. I believe you had a great post and a very detailed argument overall. Great job.
Great job with this post Mike! I agree with the decision of the court, as well as your opinion about the outcome of the case. I believe that the court’s ruling actually ensured the separation between church and state. If they would have decided that religious institutions do not have the right to decide matters of church government without state interference on discrimination issues, then that would lead to an excessive entanglement of government and religion; this would result in state censorship of Catholic schools, a clear violation of the Establishment clause. In my opinion, the court’s decision was the only way to uphold the Establishment clause.
I also agree with the outcome of this case. It was a really interesting case to read! I agree that since the school is private they church is allowed to intervene. As well, if the school did not fire him it would place more of a substantial burden on the school since the catholic church would no longer be associated with the school and the school would have to therefore shut down. This decision does not put a substantial burden on the teacher because he can become a teacher at a different school and still participate in his same-sex relationship. The main point is that the school is private and are eligible to do what they best see fit for their school.
Great Post! This is a super intriguing case. I agree with the decision of the court and also with you. There are a couple of reasons why I agree. For starters, I agree the school has a right to make this decision because they are a private institution. They are not receiving federal funds of any kind and there is a clear division between church and state in this situation. In addition, Payne- Elliot is not being told he can not marry an individual of the same sex, but rather the school is saying that if he chooses to do that he can not work at the Catholic school, who's main objective is to uphold the catholic religion. He has the option to stay married to someone of the same sex, but then he just needs to work somewhere else. This rule is neutral to everyone. All faculty members sign an agreement when starting off that says they will uphold the catholic school teachings in both their personal and professional lives. Since all faculty members need to do this it is not discriminatory and neutral to everyone. If this case would have went in the another direction, the result would indicate an entanglement between church and state.
I thought you gave a detailed description of the court case at hand and the opposition if the Catholic school was a public school. I agree with you and the ruling because any private institution is allowed to deem who they see fit as teachers of the school and of the faith. Churches have to uphold their religious values, so if that means letting a teacher go because of personal choices, the school should not be hold accountable. The government should should never have a say in who private institutions choose to employ. I recently mentined the “ministerial exception” because the cases involved do highlight some of the issues that can go before religion, such as discriminatin. It is a murky line with religion and discrimination, but since the institution is private, and the Constitution leans towards religion, the private school is allowed to dismiss the teacher because of his personal choice.
I think that this is a really interesting and perplexing case, and I enjoyed reading the analysis which you offered! It appears as though, constitutionally, the school is within its rights to terminate an employee based on the sexual orientation. I think that the decision would largely be based on any anti-discrimination laws in the state which this occurred, as well as precedents set by the Supreme Court in cases regarding the termination of employees based on lifestyle choices that conflict with their employer's religion. I think that the outcome of this case could be dependent on the state which it occurs due to those reasons. I think that Alexandra raises a good point in the Pope's statement; because that was made to be a clear modern belief of the church, could this now be discrimination? I think that this may be one of the most intricate cases which have been brought up this semester!
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