Connecticut High Court Adopts 2nd Circuit's Version of Ministerial Exception Doctrine

In Dayner v. Archdiocese of Hartford, (CT Sup. Ct., release date 8/2/2011), the Connecticut Supreme Court adopted the Second Circuit's version of the "ministerial exception" doctrine and dismissed claims by the principal of a Catholic school that she she was wrongfully terminated from her position. In reaching this conclusion the court focused on a split among circuits as to whether all employment related claims by a ministerial employee are barred, or only those that directly call into question the religious institution's hiring or termination decision. The court rejected the categorical exclusion of all employment claims and held that the only claims excluded are those which "would require the court to intrude into a religious institution’s exclusive right to decide matters pertaining to doctrine or its internal governance or organization."  All the claims here, however, met that standard.  AP reports on the state Supreme Court decision that became available yesterday. (See prior related posting.)