Biel v. St. James School, No. 17-55180 (9th Cir. 2018)
Annotate this CasePlaintiff filed suit under the Administrative Procedure Act (APA) against St. James after she was terminated from her teaching position when she told the school that she had breast cancer and would need to miss work to undergo chemotherapy. The Ninth Circuit reversed the district court's grant of summary judgment for the school, holding that, based on the totality of the circumstances test under Hosanna-Tabor Evangelical Lutheran Church & School v. E.E.O.C., 565 U.S. 171 (2012), the First Amendment's ministerial exception did not foreclose plaintiff's claim. In this case, plaintiff did not have any credentials, training, or ministerial background; there was no religious component to her liberal studies degree or teaching credential; St. James had no religious requirements for her position; and St. James did not hold plaintiff out as a minister.
Court Description: Employment Discrimination The panel reversed the district court’s summary judgment in favor of the defendant and remanded in an employment discrimination action under the Americans with Disabilities Act. Based on the totality-of-the-circumstances test articulated by the Supreme Court in Hosanna-Tabor Evangelical Lutheran Church & School v. E.E.O.C., 565 U.S. 171 (2012), the panel held that the First Amendment’s ministerial exception to generally applicable employment laws did not bar a teacher’s claim against the Catholic elementary school that terminated her employment. The panel concluded that she did not qualify as a minister for purposes of the exception. The panel considered whether the school held the teacher out as a minister, whether her title reflected ministerial substance and training, whether she held herself out as a minister, and whether her job duties included important religious functions. Dissenting, Judge Fisher wrote that, considering all of the circumstances of the teacher’s employment, she was a “minister” for the purposes of the ministerial exception
The court issued a subsequent related opinion or order on June 25, 2019.
The court issued a subsequent related opinion or order on August 20, 2020.
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