Penn v. New York Methodist Hospital, No. 16-474 (2d Cir. 2018)Annotate this Case
The Second Circuit affirmed the district court's grant of summary judgment in favor of defendants in an action alleging discrimination and retaliation against plaintiff, a former duty chaplain at New York Methodist Hospital. The court held that the district court did not err in applying the ministerial exception. In this case, the hospital, because of its history and continuing purpose, through its Department of Pastoral Care, is a "religious group," and since plaintiff's role within the Department of Pastoral Care was to provide religious care to the hospital's patients and religious care only, the ministerial exception doctrine should be applied. The court held that, once applied, the ministerial exception doctrine warranted dismissal of the suit.