Bankruptcy Court, Applying Ministerial Exception, Rejects Defrocked Priest's Claim

In In re Archdiocese of Milwaukee, (ED WI Bankr., Aug. 6, 2014), a federal bankruptcy court held that the ministerial exception doctrine requires dismissal of a claim by by a defrocked Catholic priest for back pay and related amounts.  Marvin Thomas Knighton filed the claim in the bankruptcy reorganization of the Milwaukee Archdiocese, alleging that he was removed from the ministry after a canonical trial even though a state court jury found him not guilty of second degree sexual assault of a child. The court said in part:

[T]he First and Fourteenth Amendments permit hierarchical religious organizations to establish their own rules and regulations for internal discipline and government, and to create tribunals for adjudicating disputes over these matters. When this choice is exercised and ecclesiastical tribunals are created to decide disputes over the government and direction of subordinate bodies, the Constitution requires that civil courts accept their decisions as binding upon them.... Accordingly, this Court cannot second-guess whether the Debtor followed applicable law - whether Canon Law or federal employment discrimination law - in terminating or failing to compensate Mr. Knighton.

The court also found that the claim was barred by the statute of limitations and additionally rejected Knighton's suggestions of racial discrimination.