Dean's Contract Claim Not Barred By Ministerial Exception

In Sumner v. Simpson University, (CA App., Sept. 25, 2018), a California appellate court summarized its holding in a case brought by the former dean of Tozer Seminary who was terminated for insubordination:

[T]he trial court correctly concluded that Simpson University is a religious organization and that Sumner is a minister for purposes of the ministerial exception, but that her contract cause of action is not foreclosed by the ministerial exception. Defendants have failed to show that resolution of Sumner’s contract claim would excessively entangle the court in religious matters. However, her tort causes of action are part and parcel of the actions involved in her termination, and are therefore barred by the ministerial exception.