In Obienu v. Archdiocese of New Orleans, (ED LA, Dec. 11, 2025), a Louisiana federal district court held that a former priest's Title VII claims against his archdiocese are barred by the ministerial exception doctrine. Plaintiff, a United States citizen of Nigerian origin, claimed that clergy in the New Orleans archdiocese mistreated him in a number of ways. Plaintiff filed this Title VII action alleging wrongful termination, failure to promote, failure to allow him to complete the training necessary for promotion, unequal terms and conditions of employment, and retaliation. The court said in part:
Defendants argue that Obienu’s employment discrimination claims are barred because “this lawsuit arises out of a disgruntled former priest’s dissatisfaction with how [the ANO] managed his role as a minister within its system of religious governance.” ...
... [Obienu] contends that summary judgment is not warranted because there are factual disputes whether “the adverse employment actions at issue stemmed not from religious doctrine but from national-origin discrimination, disparate treatment, and retaliation after reporting mistreatment.”...
With the Fifth Circuit’s broad pronouncement in McRaney [v. North American Mission Board of the Southern Baptist Convention] ... that the ministerial exception bars secular courts from considering Title VII and related state-law employment claims brought by a minister against a religious organization, this Court is bound to conclude that Obienu’s remaining employment discrimination claims against Defendants must be dismissed. It is undisputed that Obienu was, at all relevant times, either a Roman Catholic priest or training to be one. All the incidents he alleges constitute “employment discrimination” arose while he was training or working under the auspices of the ANO either as a seminarian or as an ordained priest. Further, the persons who he says acted unlawfully were themselves ordained priests or the archbishop.
