In
Penn v. New York Methodist Hospital, (SD NY, Jan. 20, 2016), a New York federal district court invoked the ministerial exception doctrine to dismiss a discrimination suit brought by an African-American Methodist pastor employed as a part-time chaplain by a Methodist hospital. Plaintiff claimed that he was not promoted to a vacant full-time position because of his race and religion. The court held that the hospital is a "religious institution" for purposes of the ministerial exception doctrine even though it had severed its formal ties with the United Methodist Church:
Severing a formal affiliation with the Church does not necessarily imply that the Hospital does not maintain any church-based relationship or have any religious characteristics.
It went on to find:
insofar as Plaintiff is a Methodist and was responsible—at least in part—for preaching the Christian faith, the relationship between Plaintiff and NYMH (specifically, the pastoral care department) was that of a religious employee and a religious institution. This case does not present the Court, nor will the Court venture out to decide, whether this holding would apply to a religious institution’s employment of a minister, pastor, or chaplain of a different faith.
