2nd Circuit Adopts Ministerial Exception In Title VII Racial Discrimination Case

In Rweyemamu v. Cote, (2d Cir., March 21, 2008), the U.S. 2nd Circuit Court of Appeals formally adopted the ministerial exception to claims under Title VII of the 1964 Civil Rights Act, holding that the doctrine is required by the First Amendment. In the case, the Court dismissed a Title VII racial discrimination lawsuit brought by an African-American Catholic priest against his bishop and the Diocese of Norwich, Connecticut. The priest claimed that defendants misapplied canon law in denying him a promotion and in eventually firing him, decisions that he says were racially motivated. An internal church appeal found that there were a number of legitimate grounds for the priest’s dismissal, including complaints about his homilies and about his interaction with parish staff. There was also evidence that his work with a non-profit organization he founded interfered with his full-time parish duties. The Court said that it need not decide the exact scope of the ministerial exception because Father Justinian Rweyemamu’s claim easily falls within it. The Court could not decide his claim without becoming impermissibly entangled with religious doctrine. (See prior related posting.)