Ministerial Exception Applied To FMLA Claim

In Fassl v. Our Lady of Perpetual Help Roman Catholic Church, 2005 U.S. Dist. LEXIS 22546 (ED Pa., Oct. 4, 2005), a Pennsylvania federal district court applied the “ministerial exception” to dismiss a claim by a church Music Director under the Family and Medical Leave Act of 1993. The court held that the ministerial exception, required by the First Amendment’s Free Exercise and Establishment Clauses, applies to all federal employment statutes, not just to Title VII and the ADA.