Gender Discrimination Claim By Former Pastor Dismissed Under Ministerial Exception Doctrine

In Barton v. Mikelhayes, 2010 U.S. Dist. LEXIS 107233 (ND NY, Oct. 7, 2010), a New York federal district court applied the ministerial exception doctrine to dismiss a Title VII gender discrimination complaint brought by Todd David Barton, a former minister in the United Methodist Church, whose pastoral license was withdrawn by the bishop.  The Church claimed that the action was taken, pursuant to its Book of Discipline, because of patterns of behavior by Barton that undermined the ministry of his church's Lead Pastor. The court said: 

[I]n order to decide the case ... the Court would be forced to question the Church's administration in order to decide whether Plaintiff's pastoral license was revoked due to his violation of the United Methodist Church's governing doctrine, as Defendant claims, or whether the Defendant's reasons for deciding that Plaintiff violated the doctrine were actually "not only erroneous, but also pretextual" as Plaintiff claims. This question cannot not be answered by the Court without impermissible entanglement with the United Methodist Church's religious doctrine.