John Doe Case & "Ministerial Exception" - Free Exercise of Religion

FACTS: 

    In the case “John Doe v. Catholic Relief Services”,  John Doe (“Doe”) claims that Catholic Relief Services (“CRS”) practiced discrimination based on sexual orientation. Doe claims this discrimination violated the Civil Rights Act, which protects historically oppressed demographics, including sexual orientation. In 2016, Catholic Relief Services hired this employee (anonymously referred to as John Doe) who worked until 2024. Doe was hired as a “Program Data Analyst”, and took additional roles later. Doe only worked on computer systems and managerial roles, rather than preaching Catholic doctrine. From Doe's employment, his same-sex spouse got CRS provided health benefits starting in 2016, as CRS would provide health benefits to its employees’ spouses within the first month of work. However, CRS stopped providing benefits for Doe’s same-sex spouse in 2017. CRS argued that, under the free exercise clause, the organization should have the right to express their faith in defiance of homosexuality by not providing spousal health benefits to Doe’s spouse. However, Doe argues that an employer’s religious exemption only allows discrimination if the employee’s job function directly contributes to religious matters for the organization. This means that, despite how CRS is a religious organization, not every employee is required to be a devout Catholic. Therefore, the ACLU argues that Doe’s employee role did not require Catholic faith, and makes any religious exemption unlawful if used to deprive his same-sex spouse of health benefits. The U.S. District Judges ruled in favor of Doe for his spouse’s entitlement to health benefits.

ISSUE: 

    The issue is: Does the free exercise clause protect CRS’s right to have religious exemption from fulfilling their employer duties toward homosexual employees? Without a religious exemption, CRS legally has to violate their religious condemnation of homosexuality.

PRECEDENTS APPLIED:

    To answer this issue, it is important to know two case precedents. The first case precedent will discuss how the “ministerial exception” allows Churches to discriminate against employees to ensure that their religion survives by being taught by credentialed ministers. Next, the second case will create a definition for a “minister”. CRS’s argument uses the “ministerial exception” of the Civil Rights Act, as the organization argues that Doe’s job function at CRS was religious in nature and therefore CRS had the First Amendment right to discriminate based on the free exercise of the Catholic religion. This rule is meant to be used by religious organizations to only hire their own denomination as clergy: priests can only be hired if they are Christian, rabbis can only be hired if they are Jewish, and imams can only be hired if they are Muslim. In the landmark case “Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC”, a teacher at a religious elementary school was determined to be a "minister" because she taught daily religion classes. Thus, the Hosanna-Tabor case shows that the “ministerial exception” applies to jobs defined as serving a core religious function. 

    The decision in the Hosanna-Tabor case was unanimous, but the Justices would soon find their definitions of “minister” to differ. As such, in the case “Our Lady of Guadalupe School v. Morrissey-Berru”, the definition of “minister” was determined by whether an employee is educating young people in the employing entity’s religious doctrine. Therefore, when applying the “ministerial exception” rule to the case “John Doe v. Catholic Relief Services”, Doe should not be defined as a “minister”. Doe is not a minister because his job function was focused on computer systems (and occasional training employees in computer systems). Overall, Doe’s job did not require educating others on religious doctrine, and so Doe would not be classified as a minister. This is the reason why CRS would not get a religious exemption if this case went to the Supreme Court.

PERSONAL ARGUMENT:

    My argument is that ministers are determined by having official clergy title, training, and specialty in religious preaching. My opinion differs from the case precedent, as my definition of a “minister” is more narrow than the definition in the Morrissey-Berru case. The Morrissey-Berru case establishes that ministers “educate” others in religious doctrine. However, I am concerned about possible arguments that working for a religious organization, even on computer systems, helps organizations with any ultimate “mission” of educating others in religious doctrine. To make sure Doe and other secular job positions are not classified as “ministers”, I agree with the dissenting opinion in the Morrissey-Berru case: “ministers” require substantial religious titles and training, and must be devoutly religious. This would strictly define ministers by their clergy position, as opposed to ministers being defined by any casual aid in teaching religious topics.