In Rohde v. Unitarian Universalist Association, (ED PA, July 11, 2025), a Pennsylvania federal district court dismissed on ministerial exception grounds a retired Unitarian minister's claims of defamation, false light, tortious interference with contract claims as well as her claim that her contract was breached by defendant's decision to remove her from Fellowship and revoke her ministerial credentials. According to the court:
In April 2021, three other Unitarian Universalist ministers filed a complaint against Rev. Rohde with the Association and claimed that she had committed “ministerial misconduct” based on social media interactions the three ministers had with her.... The ministers’ complaint alleged that Rev. Rohde “engaged in ‘defamation’ of colleagues, breaking of ‘confidentiality,’ and other unspecified ‘professional conduct’ violations.”...
The Committee’s “Executive Committee” determined that Rev. Rohde had committed “ministerial misconduct” and recommended that the full Committee remove her from Fellowship and revoke her ministerial credentials.... After a hearing on October 2, 2022, the Committee voted to remove Rev. Rohde from Fellowship and to revoke her ministerial credentials....
The question of whether Rev. Rohde in fact committed ministerial misconduct and violated ministerial ethics would involve the Court in measuring Rev. Rohde’s conduct against church doctrine and second-guessing the Association’s disciplinary processes for ministers. The First Amendment prohibits the Court from weighing in on such issues....
However, the court held that the ministerial exception doctrine did not bar plaintiff's claim for payment of her retirement benefits, saying in part:
... [T]he Court can resolve both Rev. Rohde’s breach of contract claim and promissory estoppel claim without analyzing doctrine or impacting the Association’s ability to choose its ministers. Rev. Rohde does not allege—and the Association’s bylaws and the Committee’s rules and policies do not show—that she was required to remain in Fellowship after retiring to continue receiving her “past earned” benefits.... Therefore, the ministerial exception does not bar Rev. Rohde’s breach of contract or promissory estoppel claims against the Pension Society at this stage.
