In Coates v. Roman Catholic Diocese of Savannah, (MD GA, April 6, 2026), a Georgia federal district court refused at this point in the litigation to dismiss on ministerial exception grounds claims of racial discrimination in employment brought against a Catholic school by an African American 1st grade teacher. The court said in part:
... [T]he amended complaint plausibly alleges Coates did not serve a ministerial function at SPCCS [St. Peter Clavar Catholic School]. Coates alleges that before her employment with SPCCS even began, Coates told Hillig [the school's principal] she was not Catholic and would not accept employment if it would require her to “participate in Catholic doctrine or worship services.”... Hillig responded by assuring Coates that religious instruction would not be her responsibility and that she would only need to escort the students to Mass on Wednesdays and monitor behavior.... During Coates’ employment, Coates did not teach religion or lead students in worship or prayer.... Nor did she participate in “Catholic worship or practices.” ... Yet, Coates received positive performance reviews....
To be sure, the complaint also alleges facts suggesting Coates may have served a ministerial role at SPCCS. Coates signed an employment contract designating her role as “ministerial” and requiring her to model the Catholic faith regardless of religion..... Still, on a motion to dismiss, Coates’ need only plausibly allege she served a non-ministerial function.... Coates has alleged facts suggesting that, despite SPCCS’ formal designation of Coates’ position as ministerial, SPCCS did not actually expect Coates to perform ministerial functions at the school, and ...accepted Coates until she participated in a police investigation against another teacher. Perhaps, as discovery develops, the undisputed facts will show that SPCCS, like most religious schools, has a sincere mission to promote religious education, and that Coates, even as a non-Catholic, served a vital role in that mission. But because the amended complaint plausibly alleg[es] that Coates’ position was non-ministerial, Defendants’ motion to dismiss her employment claims on the basis of the ministerial exception is DENIED...
The court dismissed plaintiff's Title VII religious discrimination claims on the basis of the religious institution exclusion in Title VII.
