Sunday, November 05, 2017

Ecclesiastical Abstention Doctrine Does Not Bar School Administrator's Contract Claim

In Saint Augustine School v. Cropper, (KY Sup. Ct., Nov. 2, 2017), the Kentucky Supreme Court held that the ecclesiastical abstention doctrine does not prevent the former lay administrator of a Catholic elementary school from asserting a breach-of-contract claim, saying in part:
Saint Augustine's justification for the Cropper's dismissal stems from declining student enrollment and shrinking revenues. No matter the extent of Cropper's involvement in the religious life of Saint Augustine; adjudicating her damages claim for breach of her employment contract does not require the secular court's "wading into doctrinal waters"; it is simply the termination of the lay administrator at a parochial school. Even if Cropper had been a prominent actor in the religious life of the community, unless Saint Augustine- fired her for reasons associated with the application of church doctrine or governance, the ecclesiastical-abstention doctrine would not apply.
In the case, the school had specifically disclaimed reliance on the ministerial exception defense.