In Bogan v. Mississippi Conference of the United Methodist Church, 433 F. Supp. 2d 762 (SD MI, May 5, 2006), a Mississippi federal district court rejected a racial discrimination claim filed under Title VII by an African-American pastor who argued that he and other African-American pastors had not been promoted to higher paying church positions because of their race. They were offered positions only with churches that had majority African-American members, and which generally paid less than other churches. He also claimed that he was placed on administrative leave for absences from his parsonage while Caucasian pastors were not similarly penalized. However the court held that the "ministerial exception" to Title VII, rooted in first Amendment concerns, required it to dismiss the case. It also rejected plaintiff’s attempt to rely on the Religious Freedom Restoration Act.
In Ajabu v. St. James United Methodist Church, 2006 U.S. Dist. LEXIS 55014 (MD GA, Aug. 8, 2006), a Georgia federal district court relied on the ministerial exception to Title VII to dismiss a case brought by a black pastor who claimed that he was terminated as Associate Pastor of a white church for racial reasons, and that the church's claim of doctrinal differences was merely a pretext.
