Keshel S. Coates is an African American, non-Catholic woman employed as a first-grade teacher at St. Peter Claver Catholic School (SPCCS). Coates brought this case against the Roman Catholic Diocese of Savannah (RCDS), SPCCS, Principal Sister Cheryl Hillig, and the school Superintendent Carrie Jane Williamson. She alleged nine counts of allegations against the group, of which the major allegations were race and religious discrimination, constitutional violations, and a breach of contract.
Coates stated that during her interview, she informed Hillig that she would not worship as a Catholic. Hillig allegedly assured her and stated that she would only need to escort students to Mass, while another teacher handled religious instruction. Despite these assurances being only verbal, Coates signed employment agreements stating that her employment was conditional and rested on her adhering to Catholic tenets, thus acknowledging her role was "Ministerial." Throughout her time on the job, Coates received positive reviews and initially did not participate in religious rituals, as she stated she would not. However, she alleges that Hillig eventually pressured her to participate in religious rituals, such as requiring all faculty, religious and non-religious, to receive ashes on Ash Wednesday.
In April of 2024, Coates provided a police statement regarding an incident involving another teacher and a student. Afterward, she alleges she faced increased scrutiny and "fabricated allegations." Then, on May 29, 2024, a month later, Coates was informed her contract would not be renewed by SPCCS. The reason given was her failure to "fully participate in the religious aspects" of the school program, which she alleged was verbally promised she wouldn’t have to do. Coates then filed a lawsuit based on nine expressed counts, of which three, in relation to religious discrimination under Title VII, were dismissed. Three more, in relation to employment discrimination and retention, proceeded, and the final three were dismissed as well.
The US District Court for the Middle District of Georgia dismissed Coates’ claims for religious discrimination under Title VII. Title VII contains an express exemption allowing religious educational institutions to employ individuals based on their religious beliefs. Because SPCCS is a religious institution, it is legally permitted, in some ways, to discriminate based on religion for work connected to its activities. Thus, Coates' claims of religious discrimination were denied by the Court.
Williamson et al. argued that the "ministerial exception," which prevents courts from interfering in how religious groups select their leaders, should be able to block all of Coates’ employment claims. However, upon examining the role required of Coates, the Court found that while Coates’ contract called her a "minister," she had reasonably claimed that her duties in practice were secular. She did not teach religion or lead prayer in any way, and SPCCS allegedly accepted her non-participation for two years. Due to the fact that it was plausible she served a non-ministerial function, the motion to dismiss her employment claims was denied by the court.
Lastly, Coates alleged that there were violations of her First and Fourteenth Amendment rights via 42 U.S.C. § 1983. However, the Court found that section 1983 only applied to "state actors" acting under color of law. SPCCS was considered a private entity; thus, the Court ruled that receiving federal funds or being subject to state accreditation does not turn a private school into a state actor. Ultimately, this meant that the claims made by Coates via section 1983 were dismissed. In the end, the court chose to proceed with the claims on Racial discrimination (Title VII/§ 1981), retaliation claims, and state law claims/breach of contract.
Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC is an important case to look toward when thinking about how the ministerial exemption is being discussed in Coates v. Williamson et al. Historically, the court has decided the role of “ministerial” through the actions and duties of the individual in question. Contrary to Perch in Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, the court found that although the role upon hiring was ministerial, the role in practice was not religious. Coates was restrained from getting involved with any religious practices within her duties; this was judged differently from Perch, who was deeply involved with both the religious and secular parts of her job. Furthermore, Perch was a leader within the church and school communities and acted as a direct public representation of the Hosanna-Tabor Evangelical Lutheran Church and School.
Another important case that played a role in this decision is Our Lady of Guadalupe School v. Morrissey-Berru, which was quoted by the judge when making the decisions for Coates v. Williamson et al. Following the decision in Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, the court reinforced its evaluation of the role of a minister. The Court’s decision in Morrissey-Berru led to the expansion of ministerial exemption as it held that the formal title of ministerial doesn't matter as much as function, and even teachers with relatively limited religious duties can fall under the exception. I believe Coates’ greatest challenge will be centered around her duty being non-religious, but her signing agreements which label her official capacity as ministerial. As she agreed to the role and the weight the title bears. Furthermore, the agreement stated that teachers would serve as “a Catholic role model, both inside and outside the classroom, regardless of his/her personal beliefs or different religious affiliation.”
Coates also technically failed to meet the criteria given by the school; thus, her termination was indeed valid. The court may be able to find evidence of retaliation, but when looking at whether the claim is reasonable, I believe that it is. Coates' claim to a verbal agreement holds little to no weight against written agreements; thus, I do not believe this aspect of the case will be ruled in her favor. With the decisions made in Our Lady of Guadalupe School v. Morrissey-Berru and Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, I believe that Coates has some chances of winning the case, but I can also make various points in which she may not.
6 comments:
Thank you for this analysis! I think Coates may have a strong chance of winning the case given the definition of a minister established by previous cases. If a ministerial exemption can be given to someone with little religious duties, then Coates may be eligible to count as a minister even if she does not practice the religious traditions at the school. Further, if a ministerial position is more about function, then Coates' function in educating children at a catholic school may also qualify her job to count as a ministerial position. Even though she is not religious, her role in educating children in a religious setting is still evident. If she can make the argument that her role was valid as a ministerial role then I think she has a chance of winning the case.
I disagree. Coates' agreement to be "a Catholic role model" should not require "non-religious" to participate in rituals, which could risk employee comfort. I concede that SPCCS is a "private entity", and is not required to uphold as many employee rights as public counterparts. However, merely implicit expectations of religious adherence should not justify proselytizing openly "non-Catholic" employees with the coercive threat against their job security. "Catholic role models" respecting Catholic beliefs deserve respect too.
This is a very interesting case. I especially appreciate your background and examples from other cases depicting what it means to hold a "ministerial" position. While I agree with you that spoken expectations are harder to prove than written documentation, I think that can be a slippery slope phenomenon. Coates' argument that she was hired, despite her non religious affiliation, is a very important one because it it moves past the specification that religious institutions have the right to hire based on religious affiliation. In this case, the school did not do so, and she worked there subsequently for two years without any obligation to be part of the religious educational experience. For that reason, I might disagree with you in that her argument is invalid, because while she may not have written proof of the initial conversation, her existence and work at the job demonstrates her spoken agreement during the interview, rendering them valid in my opinion.
I agree! This case largely turns on how the ministerial role is defined in practice. As Najwa says, even though Coates signed a contract labeling her position as ministerial, her actual duties were mostly secular, which makes the court’s refusal to fully apply the ministerial exception reasonable.
I agree with you Najwa! Just as James mentioned, because her duties were primarily secular, they can be viewed in a different light than her religious duties. Similar to other cases we have discussed this semester, there can be a separation of both professional and personal life. While Coates is operating in a semi-professional sense, she has personal duties that are required to operate in her professional capacity and can be judged in a different light.
I can definitely appreciate your emphasis on the importance of written contracts, however, you may be understating how courts (particularly since Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC and Our Lady of Guadalupe School v. Morrissey-Berru), have treated actual job duties. If Coates had been performing a secular role for more than two years, then the actual work performed could carry more weight than any "ministerial" label. The inconsistency between what was expected of Coates and what was enforced further supports her claims of retaliation and discrimination.
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