In Pulsifer v. Westshore Christian Academy, (6th Cir., July 9, 2025), the U.S. 6th Circuit Court of Appeals held that the ministerial exception doctrine required dismissal of an employment discrimination suit brought by the Dean of Students/ Assistant Principal of a Christian elementary school in Muskegon Heights, Michigan. The court said in part:
No one disputes that the Academy is the type of religious entity that can avail itself of the exception.... The Academy sees its role in inculcating the Christian faith as essential to its students’ salvation, and its “mission of Christian ministry and teaching” marks the school with “clear [and] obvious religious characteristics.”...
The question, then, is whether Pulsifer was the type of employee covered by the exception. We hold that he was. Pulsifer played an important role in furthering the school’s mission to provide for the religious education and formation of students. Judicial review of the way in which the Academy chooses who should fill that type of role “would undermine the independence of religious institutions in a way that the First Amendment does not tolerate.”,,,
... Pulsifer played a role in teaching the faith. He was tasked with leading the staff in religious devotions each morning and also led devotions at each meeting of the school’s board. Pulsifer also played an important role in conducting communal prayer with staff and board members.... And by implementing and leading two religious youth programs, he played a public-facing “role in conveying” the school’s religious “message,”,,,
... Put simply, an employee can fall within the ministerial exception even when “[m]ost” of their “work [is] secular in nature,” ... so long as the employee, like Pulsifer, also performs the types of religious duties we outline above. Accordingly, the district court properly granted the Academy’s motion for summary judgment.
