In Prince of Peace Lutheran Church v. Linklater, Case No. 66, 2011 WL 4374963 (Md. Sept. 21, 2011), the Maryland Court of Appeals ruled that the ministerial exception doctrine did not preclude a former music director from asserting all county-code based sexual harassment claims against her church, pastor, synod and bishop, because the church did not claim that there was any doctrinal reason for the alleged harassment. The court permitted a hostile work environment and gender discrimination claim to go forward based on allegations, inter alia, that defendants posted to a bulletin board a defaced picture of her “horribly stabbed numerous times.” The court ruled that the ministerial exception doctrine prohibited a quid pro quo sexual harassment claim, because the latter “would necessitate an evaluation of [plaintiff’s] job performance, which would run afoul of the ministerial exception.” Over vigorous dissent, the court ruled that the plaintiff could not premise her claim on the church pastor’s speech informing the church congregation of the pending lawsuit and proclaiming his innocence of misconduct. The court also held that the ministerial exception doctrine precluded plaintiff’s claims for retaliatory harassment, constructive discharge, intentional infliction of emotional distress, negligent retention and supervision, breach of contract and breach of implied contract, because evaluation of these claims would require inquiry into various employment actions taken by the church and matters of church governance and discipline.