Thursday, September 06, 2018

3rd Circuit Will Not Adjudicate Pastor's Breach of Contract Claim

In Lee v. Sixth Mount Zion Baptist Church of Pittsburgh, (3d Cir., Sept. 5, 2018), the U.S. 3rd Circuit Court of Appeals refused to adjudicate a terminated minister's breach of employment contract claim, saying in part:
The Church argues that Lee materially breached the Agreement by failing to provide adequate spiritual leadership, as reflected in decreased church contributions and attendance during Lee’s tenure....
While the amount of church contributions and members is a matter of arithmetic, assessing Lee’s role, if any, in causing decreased giving and reduced membership in the Church requires a determination of what constitutes adequate spiritual leadership and how that translates into donations and attendance—questions that would impermissibly entangle the court in religious governance and doctrine prohibited by the Establishment Clause....
Moreover, parsing the precise reasons for Lee’s termination is akin to determining whether a church’s proffered religious-based reason for discharging a church leader is mere pretext, an inquiry the Supreme Court has explicitly said is forbidden by the First Amendment’s ministerial exception. Hosanna-Tabor....
Becket Fund issued a press release announcing the decision. Pittsburgh Post Gazette reports on the decision.