Teacher's ADA Claim Dismissed Under Ministerial Exception

In EEOC v. Hosanna-Tabor Evangelical Lutheran, 2008 U.S. Dist. LEXIS 85719 (ED MI, Oct. 23, 2008), a Michigan federal district court dismissed a retaliation claim under the Americans with Disabilities Act brought by a "called" teacher holding the title of "commissioned minister" in a Lutheran school. It held that the teacher must be considered a ministerial employee. It found that the "ministerial exception" for religious employers applies to ADA claims as well as Title VII claims.