In Lee v. Sixth Mt. Zion Baptist Church of Pittsburgh, No. 17-3086, 2018 WL 4212091 (3d Cir. Sept. 5, 2018), the court of appeals affirmed the district court's application of the ministerial exception doctrine barring it from ruling in favor of a former pastor with respect to his breach of employment contract claim. The pastor entered into a 20-year term contract with the church, but 20 months later, the church terminated him for three reasons: (1) failures in financial stewardship, (2) failures in spiritual stewardship and (3) failures to respond to church leaders. The court found that "[w]hile the amount of church contributions and members is a matter of arithmetic, assessing Lee's role, if any, in causing decreased giving and reduced membership in the church requires a determination of what constitutes adequate spiritual leadership and how that translates into donations and attendance—questions that would impermissibly entangle the court in religious governance and doctrine prohibited by the Establishment Clause.... Moreover, parsing the precise reasons for Lee's termination is akin to determining whether a church's proffered religious-based reason for discharging a church leader is mere pretext, an inquiry the Supreme Court has explicitly said is forbidden by the First Amendment's ministerial exception."
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Ministerial Exception Doctrine Bars Former Pastor's Breach of Contract Claim
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