In Middleton v. United Church of Christ, (ND OH, Aug. 26, 2020), an Ohio federal district court held that the ministerial exception doctrine does not preclude a minister bringing a hostile work environment claim, at least where the claim does not involve the court in excessive entanglement with religious matters. The court said in part:
[A]fter examining Middleton’s first cause of action, the court concludes that it does not implicate “any matters of church doctrine or practice.” ... Middleton’s hostile workplace claim involves allegations of racial and gender harassment that are wholly unrelated to Defendants’ religious teachings. ....
Nevertheless the court went on to dismiss the hostile work environment claim, saying in part:
While Middleton describes interactions that are unprofessional and unpleasant, none of the alleged conduct was physically threatening or humiliating. At most, these sporadic comments constituted “offensive utterances,” which “do not rise to the level required by the Supreme Court’s definition of a hostile work environment.”
The court held that plaintiff's breach of contract and promissory estoppel claims were barred by the ministerial exception doctrine. [Thanks to Heather Kimmel for the lead.]
