In MoChridhe v. Academy of Holy Angels, (MN App. Dec. 1, 2025), a Minnesota state appellate court rejected an employment discrimination claim by a former media specialist/librarian at a Catholic school. The school refused to renew her contract when she disclosed that she was undergoing gender transition to present as a female. The school based its decision on MoChridhe's refusal to abide by the "Guiding Principles for Catholic Schools and Religious Education Concerning Human Sexuality and Sexual Identity." The court said in part:
Does the First Amendment protect a religious employer from discrimination claims by a terminated non-minister employee if the termination was based on a religious reason? Given the facts alleged in MoChridhe’s complaint and the absence of any binding precedent suggesting otherwise, we discern no basis to conclude that the broader religious protections of the First Amendment church autonomy doctrine are not available to the religious employer in that situation....
... [C]onsideration of MoChridhe’s claims would require consideration of the Archdiocese’s religious reason for the employment decision, would interfere with the Archdiocese’s internal decision to require compliance with the Guiding Principles in the school setting—which relates to the church’s mission to educate young people in its faith— and would foster excessive governmental entanglement with religion. The potential inapplicability of the ministerial exception does not change that conclusion, and there is no precedent indicating that it must...
